It is well known that a nonresident plaintiff cannot assert “specific” personal jurisdiction over a nonresident defendant unless that plaintiff was injured in the forum state. As a result, nonresident plaintiffs traditionally have relied on general jurisdiction principles to maintain an action against a nonresident defendant in the plaintiff’s favored jurisdiction. The Supreme Court’s decision in Daimler AG v. Bauman, 134 S. Ct. 746 (2014), has severely curtailed general personal jurisdiction and, thus, the ability of nonresident plaintiffs to maintain claims against nonresident defendants.
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