If your company has a foreign parent, or you’re a foreign manufacturer who sells into the United States through an American subsidiary, you’ve probably assumed that the subsidiary’s heavy California business pulls the parent into California courts too. It feels obvious. But the California Court of Appeal just confirmed it doesn’t work that way, and the ruling gives cross-border companies real protection against being dragged into a California courtroom.
The decision is Fanuc Corp. v. Superior Court (Cal. Ct. App., 4th Dist., Div. 2, Oct. 9, 2026), and it turns on personal jurisdiction, the legal power a court needs over a defendant before it can enter a binding judgment against it. The injured worker here had a sympathetic case. He still lost the jurisdiction fight, because the law asks a narrower question than most people expect.
How a Robot Injury Became a Jurisdiction Fight
Abraham Bernal was a maintenance technician at a Niagara Bottling plant. In June 2020, while he was securing a ladder beneath a machine’s gripper head suspended 15 to 20 feet above the floor, the machine released the head and severely injured him. A robot made by Fanuc Corporation, a Japanese company, had malfunctioned during the same incident. Bernal sued the Japanese manufacturer along with its American subsidiary, Fanuc America, a Delaware corporation headquartered in Michigan.
Fanuc America didn’t contest being sued in California. Fanuc Japan did. It filed a motion to quash, the procedural tool a defendant uses to argue a court has no power over it, pointing out that it has no California office, no California property, no California bank accounts, and no registration to do business here. The trial court let the case proceed anyway, reasoning that the parent could be reached through its subsidiary. The Court of Appeal disagreed and reversed.
Why Personal Jurisdiction Didn’t Reach the Foreign Parent
Courts recognize two ways to acquire personal jurisdiction. General jurisdiction, which lets a court hear any claim against a defendant, exists only where a company is “essentially at home,” meaning, for a corporation, its state of incorporation or its headquarters. Specific jurisdiction is narrower and applies only when the lawsuit itself arises out of the defendant’s contacts with the state.
Bernal’s theory was that Fanuc America’s California activity should be attributed to Fanuc Japan, making the parent “at home” here. The court rejected it for a clean reason. Even if you treat the subsidiary’s contacts as the parent’s, Fanuc America itself isn’t “at home” in California, because it’s incorporated in Delaware and headquartered in Michigan. A subsidiary that isn’t at home in the forum can’t anchor all-purpose jurisdiction over its foreign parent, whether the theory is agency (one company acting for another) or alter ego (treating two companies as one because the corporate separation is a sham). The court also noted that the U.S. Supreme Court’s Daimler decision gutted the older California cases that let plaintiffs reach foreign parents through a “representative services” theory, so that route is effectively closed.
The Injury Has to Connect to the Company’s California Contacts
That left specific jurisdiction, and here the court focused on a requirement called relatedness: the plaintiff’s injury has to arise out of or relate to the defendant’s contacts with California. Even assuming Fanuc Japan reached into the state through its subsidiary, Bernal couldn’t clear that bar. The specific robot model that hurt him was sold in Europe to the company that built the larger machine, not in California. Bernal pointed to Fanuc America’s three California service centers and to his employer’s purchase of other Fanuc robots. But neither fact showed that this robot’s alleged defect connected to Fanuc’s California business. Selling other products here, and running repair shops here, doesn’t create jurisdiction over a product that was never shown to be marketed, sold, or installed in the state.
What This Means for Companies With Cross-Border Structures
If you operate through a parent-subsidiary structure that crosses borders, the protection here is concrete. Your American subsidiary can do substantial business in California without exposing the foreign parent to all-purpose jurisdiction, as long as the subsidiary is incorporated and headquartered somewhere else. That’s a planning point, not just a litigation outcome. Where you incorporate and base a U.S. subsidiary shapes where the parent can be sued.
For companies defending product claims, relatedness is a gate worth using. A plaintiff has to tie the specific product that caused the harm to your contacts with the forum, and a generalized market presence won’t do it. And for anyone on the other side, bringing the claim, the lesson is to build the jurisdictional record around the actual product, its actual sales, and its actual path into the state, not the defendant’s overall footprint.
The Bottom Line
Corporate structure is risk management, and this decision shows how much can ride on where a subsidiary is incorporated and based. A foreign parent isn’t automatically suable in California just because its U.S. arm sells heavily here, and a product claim won’t reach a foreign manufacturer unless the specific product is tied to that manufacturer’s California contacts. Companies with cross-border structures should map their jurisdictional exposure before a lawsuit forces the question, and companies facing product claims should test relatedness early. Horst Legal Counsel advises businesses on jurisdictional strategy, cross-border litigation risk, and the defense of product and personal injury claims. If you want to understand where your company, or its parent, can actually be sued, we’re glad to talk it through.