Ranza v. Nike, Inc., No. 13-35251 (9th Cir. 2015)
Annotate this CasePlaintiff filed suit against her former employer NEON and NEON's parent company (Nike, Inc.), alleging sex and age discrimination in violation of Title VII of the Civil Rights Act of 1964, 42 U.S.C. 2000e-2, 2000e-3, and the Age Discrimination in Employment Act of 1967 (ADEA), 29 U.S.C. 623. Plaintiff filed in the District of Oregon. Neon's parent company is headquartered in Oregon, but the alleged discriminatory conduct occurred in the Netherlands. The district court dismissed the claims. The court held that NEON’s contacts with the state of Oregon are insufficient to make it amenable to general personal jurisdiction there, pursuant to Daimler AG v. Bauman. The court also held that a court may attribute a parent company's contacts with the forum state to its foreign subsidiary for the purpose of exercising personal jurisdiction over the subsidiary upon a showing that the subsidiary is an alter ego of its parent, consistent with Doe v. Unocal Corp. In this case, plaintiff has not shown that NEON is Nike’s alter ego. Accordingly, the court affirmed the dismissal of the claims against NEON for lack of personal jurisdiction and affirmed the dismissal of the claims against Nike under the doctrine of forum non conveniens because the Netherlands provides a more convenient forum than Oregon to hear plaintiff's claims. The Dutch Equal Treatment Commission is an adequate alternative forum and it has already considered and rejected plaintiff’s claims.
Court Description: Personal Jurisdiction/Forum Non Conveniens. The panel affirmed the dismissal, on grounds of lack of personal jurisdiction and forum non conveniens, of a complaint alleging sex and age discrimination in the workplace in violation of Title VII and the Age Discrimination in Employment Act. The alleged discriminatory conduct occurred in the Netherlands. The panel held that the contacts with Oregon of the plaintiff’s employer, a foreign subsidiary of Nike, Inc., were insufficient to make the subsidiary amenable to general personal jurisdiction there. In addition, the plaintiff did not show that the subsidiary was an alter ego of Nike, and thus that the district court could attribute Nike’s contacts with the forum state to the foreign subsidiary for the purpose of exercising general personal jurisdiction over the subsidiary. The panel affirmed the dismissal of claims against Nike under the doctrine of forum non conveniens because the Netherlands provided a more convenient forum than Oregon, and the Dutch Equal Treatment Commission was an adequate alternative forum and had already considered and rejected the plaintiff’s claims. RANZA V. NIKE 3
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