For many lawyers, one of the most indelible lessons of first-year civil procedure class was that a corporation that engages in substantial business in a state is subject to general personal jurisdiction there—that is, it can be sued there on any claim, even if unconnected to the state.

But in 2014, the Supreme Court held in Daimler v. Bauman, 134 S. Ct. 746 (2014) that finding general jurisdiction anywhere the defendant did business would be “unacceptably grasping.” Thus, the court held that, as a matter of due process, outside of an “exceptional case,” a corporation can only be subject to general jurisdiction in its state of incorporation or where it has its principal place of business. Id. at 760–61, n.19

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