Perkins v. Benguet Consolidated Mining Company

In Perkins v. Benguet Consolidated Mining Company, 342 U.S. 437 (1952), a company's president, who was also its general manager and principal shareholder, maintained an office in Ohio in which he "did many things on behalf of the company." Perkins, 342 U.S. at 447-48. He maintained company files in Ohio, carried on correspondence from there, drew and distributed salary checks from his Ohio office, used two Ohio bank accounts for company funds and had an Ohio bank act as transfer agent for the company's stock, held director's meetings in Ohio, supervised policies dealing with the rehabilitation of the corporation's properties in the Philippines there, and dispatched funds from Ohio bank accounts to cover purchases of machinery for such rehabilitation. Id. Under these circumstances, the Court held "it would not violate federal due process for Ohio either to take or decline jurisdiction of the corporation in this proceeding." Id. at 448. The Supreme Court upheld the district court's exercise of general jurisdiction in Ohio over a Philippine corporation. Perkins, 342 U.S. at 438. The corporation's president, who was also the general manager and principal shareholder, briefly relocated to his home in Ohio when the corporation's Philippine mining operations were halted during the Japanese occupation of the Philippine Islands. Id. at 447. The president maintained an office in Ohio "in which he conducted his personal affairs and did many things on behalf of the company." Id. at 447-48. In addition, he kept company files in Ohio, carried on correspondence relating to the company's business, drew and distributed salary checks on behalf of the company, as well as supervised policies dealing with the rehabilitation of the company's Philippine properties. Id. at 448. Based on these activities, the Court held "he carried on in Ohio a continuous and systematic supervision of the necessarily limited wartime activities of the company." Id.