Perspective
Oct. 1, 2014
For plaintiffs, foreign corporations increasingly elusive
The Supreme Court has significantly diminished the ability of plaintiffs to obtain a forum in the United States for adjudication of their claims against foreign corporations By Clyde Spillenger
In Mendoza Martinez v. Aero Caribbean, 2014 DJDAR 11448 (Aug. 21, 2014), the 9th U.S. Circuit Court of Appeals held that in-state service on an officer of a corporate defendant does not, by itself, establish constitutionally adequate personal jurisdiction over such a defendant, as it would for an individual defendant under the plurality opinion in the U.S. Supreme Court case of Burnham v. Superior Court (1990). Since the holding ...
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