Cooper Tire & Rubber Company v. McCall

Tyrance McCall, a Florida resident, was badly hurt when a Cooper Tire-made tire on his vehicle failed on a Florida road. He sued Cooper Tire, an Ohio-based company incorporated in Delaware, in a Gwinnett County state court, along with the driver and a Georgia car dealership. Cooper Tire argued Georgia courts had no authority over it because the crash happened in Florida and it had only limited ties to Georgia. A trial court agreed and dismissed the case, but the Court of Appeals of Georgia reversed, relying on a 1992 Georgia Supreme Court case called Klein, which said any out-of-state company authorized to do business in Georgia can be sued here for anything, anywhere. Cooper Tire asked the Supreme Court of Georgia to overturn Klein, arguing it conflicts with newer U.S. Supreme Court rulings limiting when states can sue out-of-state companies. The Georgia court agreed there is tension with those newer rulings but found that an older, still-valid U.S. Supreme Court case allows states to treat business registration as consent to be sued. The court also declined to overturn Klein as a matter of Georgia statutory interpretation, so Cooper Tire remains subject to suit in Georgia.

The court held that Cooper Tire, having registered to do business in Georgia, is treated as a Georgia resident for jurisdictional purposes and can be sued here on claims unrelated to Georgia, because this consent-by-registration approach still fits within an old, unoverruled U.S. Supreme Court due process rule, and because overturning the prior Georgia precedent would leave such companies immune from suit entirely.

Any out-of-state company registered to do business in Georgia can still be sued here on claims unconnected to Georgia, giving injured Georgians and others broader access to Georgia courts. But the court and a concurring justice flagged that this rule could later be struck down under federal law, and urged the legislature to update Georgia's jurisdiction statutes to avoid leaving companies immune from suit here.

Affirmed

1. The court traced U.S. Supreme Court personal jurisdiction law from Pennoyer v. Neff through Pennsylvania Fire, which held that a company can consent to being sued anywhere by registering to do business under a state law that treats registration as consent, and through International Shoe and its modern descendants like Goodyear and Daimler, which limit general jurisdiction (the power to sue a company on any claim, anywhere) mainly to a company's home state or place of incorporation.
2. Because Pennsylvania Fire has never been overruled by the U.S. Supreme Court, the court reasoned that it remains binding law even though it sits uneasily beside the newer Goodyear line of cases, so lower courts must keep following it until the Supreme Court itself says otherwise.
3. Applying that rule, the court found that Georgia's own 1992 decision, Klein, which treats a company's registration to do business in Georgia as consent to be sued here on any claim, fits within what Pennsylvania Fire allows and therefore does not violate federal due process.
4. Turning to whether Klein should be overturned as a matter of interpreting Georgia's long-arm statute (the law defining when nonresident companies can be sued here), the court applied a four-factor stare decisis test, meaning a legal rule of respecting past decisions, that weighs how sound the past reasoning was, how old the precedent is, whether anyone relied on it, and how workable it has proven.
5. The court concluded that overturning Klein would create a 'jurisdictional gap,' letting companies escape being sued in Georgia entirely just by registering to do business here, so the workability and reasoning factors favored keeping Klein in place rather than overruling it.

• personal jurisdiction
• Cooper Tire lawsuit
• tire failure injury
• corporate registration
• stare decisis