Daimler Ducks Claims Over Bad Jeep Designs
SAN FRANCISCO (CN) - German automaker Daimler's old ties to Chrysler - or current ones with Mercedes-Benz USA - aren't sufficient to allow a product liability suit over a crashed Jeep, a California appeals court held Tuesday.
Kimberly Young and her daughter suffered catastrophic injuries in 2008 after their Jeep Cherokee rolled over and the roof collapsed. In her 2010 lawsuit, Young claimed the roof and restraint systems in the Jeep were defectively designed by the DaimlerChrysler Corporation, a former indirect subsidiary of Daimler.
While Chrysler had added the Daimler name to its own in 1998, it maintained separate company headquarters in Michigan and registered as a corporation in Delaware. So Daimler moved to quash service of summons of Young's complaint, based on the California trial court's lack of personal jurisdiction over the Germany-based company.
Young argued Daimler's indirect control over its Chrysler subsidiary gave the court jurisdiction, based on a 2011 holding by the 9th Circuit Court of Appeals in Bauman v. DaimlerChrysler Corp. In that case, the court found that Daimler's relationship with another of its indirect subsidiaries - Mercedes-Benz USA, also a Delaware company - gave U.S. courts personal and general jurisdiction over the German Daimler.
But an Alameda County judge found that Young had failed to show that Daimler had been involved in the design, manufacture or sale of her Jeep Cherokee, or that Daimler exercised any control over the day-to-day operations of either Chrysler or Mercedes-Benz - and dismissed the action for lack of jurisdiction.
Young filed an appeal, but in the meantime the U.S. Supreme Court unanimously reversed the 9th Circuit's holding in Bauman earlier this year. In Bauman II, the nation's highest court reinforced a precedent it reached in Goodyear Dunlop Tires Operations SA v. Brown to bar personal injury lawsuits against foreign corporations in the interest of international fair play and due process.
In light of the Supreme Court's decision - and despite Young's arguments that Bauman II didn't examine California's rules on agency - a panel for the First Appellate District affirmed the trial court's dismissal.
"In sum, appellants cannot escape the fact that the Bauman II decision controls with the instant action and mandates the conclusion that, barring the development of new facts, 'California is not an all-purpose forum for claims against Daimler,' Judge Timothy Reardon wrote, citing Bauman II. "We therefore decline to disturb the trial court's order granting Daimler's motion to quash service of summons for lack of personal jurisdiction."