D had been operating a continuous and systematic, but limited, part of its business in OH. President was served while in OH.
P sued D in OH for dividends owed and failure to issue stock certificates to her.
The cause of action did not arise in OH and does not relate to any business activities in OH.
Procedural History:
Trial court found for D.
OH Court of Appeals affirmed, found for D.
OH Supreme Court affirmed, found for D.
SCOTUS reversed, found for P, jurisdiction valid.
Issues:
Can a state exercise personal jurisdiction over a foreign corporation when the cause of action does not arise in the state or relate to any of the corporation's activities in the state?
Holding/Rule:
A state may exercise personal jurisdiction over a foreign corporation even when the cause of action does not arise in the state or relate to any of the corporation's activities in the state if the corporation carries on continuous and systematic corporate activities in that state.
Reasoning:
The president (also GM and principal stockholder in company) returned to his home in OH during a war in the Philippines (where company was based).
While in OH, he maintained an office in which he conducted his personal affairs and did many things on behalf of the company. At that location, he kept office files, carried on correspondence relating to the business and its employees, drew and distributed salary checks, maintained bank accounts that contained company funds, held director's meetings, etc.
Thus, he carried on in OH a continuous and systematic supervision of the company.
Dissent:
Omitted.
Notes:
Case deals with general jurisdiction.
This case may have been decided this way because the P had no other U.S. forum to sue the company.
