Cooper Tire & Rubber Company v. McCall

863 S.E.2d 81, 312 Ga. 422
CourtSupreme Court of Georgia
DecidedSeptember 21, 2021
DocketS20G1368
StatusPublished
Cited by19 cases

This text of 863 S.E.2d 81 (Cooper Tire & Rubber Company v. McCall) is published on Counsel Stack Legal Research, covering Supreme Court of Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Cooper Tire & Rubber Company v. McCall, 863 S.E.2d 81, 312 Ga. 422 (Ga. 2021).

Opinion

312 Ga. 422 FINAL COPY

S20G1368. COOPER TIRE & RUBBER COMPANY v. McCALL.

LAGRUA, Justice.

We granted certiorari in this products liability action against

an out-of-state corporation to reconsider one of our holdings in

Allstate Insurance Co. v. Klein, 262 Ga. 599 (422 SE2d 863) (1992).

In Klein, we held that Georgia courts may exercise general personal

jurisdiction over any out-of-state corporation that is “authorized to

do or transact business in this state at the time a claim or cause of

action arises.” Id. at 601 (citation and punctuation omitted). As

discussed below, although Klein’s general-jurisdiction holding is in

tension with a recent line of United States Supreme Court cases

addressing when state courts may exercise general personal

jurisdiction over out-of-state corporations in a manner that accords

with the due process requirements of the United States

Constitution, Klein does not violate federal due process under

1 Pennsylvania Fire Insurance Co. of Philadelphia v. Gold Issue

Mining & Milling Co., 243 U. S. 93 (37 SCt 344, 61 LE 610) (1917),

a decision that the Supreme Court has not overruled. Thus, we are

not required to overrule Klein as a matter of binding federal

constitutional law. We also decline to overrule Klein as a matter of

statutory interpretation. Therefore, we affirm the Court of Appeals’

decision, which followed Klein.

The Court of Appeals summarized the undisputed underlying

facts and procedural history of this case as follows:

[Florida resident] Tyrance McCall sued Cooper Tire & Rubber Company (“Cooper Tire”) and two other defendants in the State Court of Gwinnett County for injuries he allegedly sustained in a motor vehicle collision. ...

McCall’s complaint alleges that on April 24, 2016, he was a passenger in a vehicle that was equipped with a rear tire designed, manufactured, and sold by Cooper Tire. As the vehicle was traveling on a Florida roadway, the tire tread “suddenly failed and separated from the remainder of the tire.” The driver lost control of the vehicle, which left the roadway and rolled over until it came to rest in a nearby wooded area. McCall sustained severe injuries in the crash. Following the collision, McCall sued Cooper Tire for

2 negligence, strict product liability, and punitive damages. He also asserted claims against the driver, a Georgia resident, and the Georgia car dealership that sold the vehicle to the driver. Cooper Tire answered the complaint, raising numerous defenses, including lack of personal jurisdiction. It also filed a motion to dismiss, arguing that as a nonresident corporate defendant with only minimal contacts in Georgia, it is not subject to personal jurisdiction in this state. An accompanying affidavit from Cooper Tire’s corporate counsel established that Cooper Tire is incorporated in Delaware and maintains its principal place of business in Ohio. McCall responded that Cooper Tire is a resident of Georgia — and thus subject to personal jurisdiction here — because it is authorized to transact business in the state. In its reply, Cooper Tire did not dispute that it has been authorized to transact business in Georgia at all times relevant to this suit. It argued, however, that such circumstances do not make it a Georgia resident for jurisdictional purposes. The trial court agreed and granted Cooper Tire’s motion to dismiss.

McCall v. Cooper Tire & Rubber Co., 355 Ga. App. 273, 273-274 (843

SE2d 925) (2020). On appeal, the Court of Appeals reversed the trial

court, concluding that under Klein, “Cooper Tire is a resident

corporation subject to personal jurisdiction in this state, [and] the

trial court erred in granting the motion to dismiss.” Id. at 275.

We granted Cooper Tire’s petition for a writ of certiorari. For

the reasons that follow, we conclude that, although Klein’s general-

3 jurisdiction holding is in tension with the trajectory of recent United

States Supreme Court decisions addressing a state’s authority to

exercise general personal jurisdiction over corporations, Klein

cannot be overruled on federal constitutional grounds.1 And,

considerations of stare decisis counsel against overruling Klein’s

holding as a matter of statutory construction. Accordingly, as held

by the Court of Appeals, Cooper Tire is currently subject to the

general jurisdiction of our courts under Klein.

1. The seminal case of Pennoyer v. Neff, 95 U. S. 714 (24 LE

565) (1878), established the parameters governing a state court’s

authority to assert personal jurisdiction over an out-of-state

defendant in accordance with the Due Process Clause of the

Fourteenth Amendment to the United States Constitution. Under

that framework, due process of law required either the “voluntary

appearance” of the out-of-state defendant or personal service of

process upon the out-of-state defendant to bring the defendant

1 We posed a threshold question to the parties asking whether the argument that Klein’s holding should be reconsidered was properly preserved in the courts below. We conclude that the issue was adequately preserved. 4 within the state’s jurisdiction and allow the defendant to be

“personally bound by any judgment rendered.” Id. at 733-734

(citation and punctuation omitted).

As recently noted by Justice Gorsuch, in the years after

Pennoyer, interstate commerce and the development of corporations

continued to rise in this country, and thus, many states faced an

increase in legal conflicts involving out-of-state corporate

defendants in their courts. See Ford Motor Co. v. Montana Eighth

Judicial Dist. Court, ___ U. S. ___ (141 SCt 1017, 1037, 209 LE2d

225) (2021) (Gorsuch, J., concurring). “States sought to obviate any

potential question about corporate jurisdiction by requiring an out-

of-state corporation to incorporate under their laws too, or at least

designate an agent for service of process.” Id. “[T]he idea was to

secure the out-of-state company’s presence or consent to suit” in that

state. Id.

During this time period, the Supreme Court issued its decision

in Pennsylvania Fire and formalized the concept of general corporate

jurisdiction by “consent.” See Pennsylvania Fire, 243 U.S. at 94. In

5 Pennsylvania Fire, an out-of-state insurance company obtained a

license to do business in Missouri and, in compliance with Missouri’s

corporate statute, Rev. Stats. Mo., 1909, § 7042, filed a power of

attorney “consenting that service of process upon the

superintendent [of the insurance department] should be deemed

personal service upon the company so long as it should have any

liabilities outstanding in the [s]tate.” Id. The lawsuit at issue was

commenced through service of process upon the superintendent, and

the insurance company argued that “such service was insufficient”

and that, “if the statute were construed to govern the present case[,]

it encountered the Fourteenth Amendment by denying to the

defendant due process of law.” Id. at 94-95. After the Supreme

Court of Missouri held that the statute was applicable and

consistent with the United States Constitution, the insurance

company appealed to the United States Supreme Court. See id. at

95.

In affirming the Missouri Supreme Court, the United States

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