Perkins v. Benguet Consolidated Mining Co.
(1952)
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Rule of Law:
The Due Process Clause of the Fourteenth Amendment does not prohibit a state from exercising personal jurisdiction over a foreign corporation in a lawsuit based on a cause of action arising outside the state, provided the corporation's business activities within the state are continuous, systematic, and substantial.
Facts:
- Benguet Consolidated Mining Company, a corporation organized under the laws of the Philippine Islands, owned and operated mines in the Philippines.
- During the Japanese occupation of the Philippines in World War II, the company's mining operations were halted.
- The company's president, general manager, and principal stockholder returned to his home in Clermont County, Ohio.
- From his Ohio office, the president conducted continuous and systematic business on behalf of the company.
- These Ohio-based activities included: holding directors' meetings, maintaining company files, carrying on business correspondence, distributing salary checks, maintaining two active company bank accounts, and supervising the rehabilitation of the Philippine properties.
- Idonah Slade Perkins, a stockholder, sued the company in Ohio for dividends and damages related to the company's failure to issue her stock certificates.
- The causes of action asserted by Perkins did not arise from the company's business activities in Ohio.
Procedural Posture:
- Idonah Slade Perkins filed two in personam actions against Benguet Consolidated Mining Company in the Court of Common Pleas of Clermont County, Ohio, a state trial court.
- The trial court granted the mining company's motion to quash the service of summons.
- Perkins, as appellant, appealed to the Court of Appeals of Ohio, an intermediate appellate court, which affirmed the trial court's decision.
- Perkins, as appellant, then appealed to the Supreme Court of Ohio, the state's highest court, which also affirmed.
- The U.S. Supreme Court granted Perkins' petition for a writ of certiorari to review the judgment of the Supreme Court of Ohio.
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Issue:
Does the Due Process Clause of the Fourteenth Amendment prohibit a state from exercising in personam jurisdiction over a foreign corporation for a cause of action that did not arise from the corporation's activities within the state, when that corporation carries on continuous and systematic business in the state?
Opinions:
Majority - Mr. Justice Burton
No, the Due Process Clause of the Fourteenth Amendment does not prohibit Ohio from exercising jurisdiction. If a foreign corporation's activities within a state are continuous and systematic, it is not unfair or unreasonable under the Due Process Clause for that state to exercise jurisdiction over the corporation, even for causes of action that are entirely distinct from those activities. Building on the fairness test from International Shoe Co. v. Washington, the Court found that Benguet's activities in Ohio—including directors' meetings, banking, stock transfers, and correspondence—were sufficiently substantial to make it amenable to suit there. The Court clarified that it was not compelling Ohio to accept jurisdiction, but merely holding that the Constitution does not prevent it from doing so, leaving the ultimate decision to the Ohio courts on remand.
Dissenting - Mr. Justice Minton
The writ should be dismissed as improvidently granted. The dissent argued that the Ohio Supreme Court's decision rested on an adequate and independent state law ground, as evidenced by its official syllabus. The fact that one judge's accompanying opinion referenced an erroneous view of federal law does not transform the case into a federal question. By deciding the case, the U.S. Supreme Court was improperly issuing an advisory opinion to the Ohio court, which is beyond its constitutional role.
Analysis:
This case establishes the doctrine of general personal jurisdiction over a corporation. It clarifies that if a corporation's contacts with a state are so 'continuous and systematic' that it is essentially 'at home' there, the state can exercise jurisdiction over it for any claim, regardless of where the claim arose. This decision expanded upon the specific-jurisdiction framework of International Shoe by creating a separate basis for jurisdiction when a defendant's in-state presence is exceptionally strong. It sets a high standard for finding a corporation subject to suit on any matter, shaping jurisdictional analysis for decades to come.
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