majority of states – 38
(plus DC and VI) – have rejected the theory that a
nonresident defendant may be subject to general jurisdiction simply
by registering to conduct business through judicial decision or by
statute, while in only 4 (Iowa, Minnesota, Nebraska, Pennsylvania)
does current precedent continue to support that suspect argument,
with the outcome being unclear in the other 8 (Alabama, Georgia,
Hawaii, Kansas, Kentucky, New Hampshire, Tennessee, Virginia, and
Wyoming). Notably, the highest courts in California,
Colorado, Delaware, Illinois, Maryland, Michigan, Missouri, New
Mexico, Nevada, North Carolina, Ohio, Oregon, and Wisconsin have
rejected such arguments, with seven of those occurring
post-Bauman.

The overwhelming number of state and federal decisions issued
after Bauman, which we have tracked
here, shows an unmistakable trend against subjecting a
nonresident defendant to a state's general jurisdiction through
registration for business. In other words, although the
Supreme Court hascheap pork roast at home, but we found ourselves being invited at the last minute (on the evening of Christmas Eve) to a friend's house. He has a very strong bond with his parents' old village home in a remote village, close to the mountains, where only about 30 people now reside permanently throughout the year.

Although N lives in the town, he keeps chickens, rabbits and sheep in the fields around the village house, which is a bit like a rabbit warren. The rooms were built one by one, as they were needed, originally by the grandfather of his grandfather. N's family were the last to reside there, as now, he and all his siblings have moved away to lower ground. The house has not been maintained as