Facts
- Kathi Buss sued Wal-Mart in Arizona superior court for negligence arising from a slip-and-fall at a Wal-Mart store in Oregon.
- Wal-Mart is incorporated in Delaware and has its principal place of business in Arkansas.
- The claim arose entirely from alleged conduct and injury in Oregon; no case-specific conduct was tied to Arizona.
- Buss argued Arizona courts had general jurisdiction because Wal-Mart had extensive retail and distribution operations in Arizona.
- Buss also argued Wal-Mart impliedly consented to general jurisdiction by registering as a foreign corporation in Arizona and appointing an Arizona agent for service of process under A.R.S. §§ 10-1501 to -1510.
- The superior court denied Wal-Mart’s motion to dismiss for lack of personal jurisdiction, relying on an earlier Arizona decision.
- Wal-Mart sought special-action relief in the Arizona Court of Appeals from the denial of its motion to dismiss.
Issues
- Whether a foreign corporation’s extensive in-state business operations, without incorporation or headquarters in the forum, render the corporation “at home” for purposes of general personal jurisdiction.
- Whether registering to do business in Arizona and appointing an in-state agent for service of process under A.R.S. §§ 10-1501 to -1510 constitutes implied consent to general personal jurisdiction.
Decision
- The Court of Appeals accepted special-action jurisdiction and granted relief to Wal-Mart.
- The court held Arizona could not exercise general jurisdiction over Wal-Mart based solely on the magnitude of its Arizona operations because Wal-Mart was neither incorporated nor headquartered in Arizona.
- The court held Wal-Mart did not impliedly consent to general jurisdiction merely by registering as a foreign corporation and appointing an agent for service of process under Arizona statutes.
- The court determined Wal-Mart was subject in Arizona only to specific jurisdiction tied to Arizona-related conduct; because the claim arose in Oregon, specific jurisdiction was unavailable.
- The court directed that the superior court’s denial of Wal-Mart’s motion to dismiss be set aside and that relief be granted consistent with lack of personal jurisdiction.
Legal Principles
- General jurisdiction over a corporation is ordinarily limited to the corporation’s place of incorporation and principal place of business; substantial forum business activity alone does not make the corporation “at home.”
- After modern due-process limits on general jurisdiction, general jurisdiction outside the paradigm forums is reserved for exceptional circumstances, not satisfied by a large commercial footprint.
- Compliance with Arizona’s foreign-corporation registration and agent-for-service statutes (A.R.S. §§ 10-1501 to -1510) does not amount to implied consent to general personal jurisdiction.
- When general jurisdiction is lacking, a forum may adjudicate claims against a corporate defendant only through specific jurisdiction, which requires the claims to relate to the defendant’s forum-related conduct.
Conclusion
Arizona courts could not exercise personal jurisdiction over Wal-Mart for an Oregon slip-and-fall claim because Wal-Mart was not “at home” in Arizona and did not consent to general jurisdiction by registering to do business and appointing an agent for service of process; only forum-related claims could proceed under specific jurisdiction.