Ever since the Supreme Court’s 2014 Daimler AG v. Bauman decision barred state courts from asserting “general” personal jurisdiction over nonresident corporations, plaintiffs’ lawyers have been searching for new jurisdictional theories that will permit them to continue to bring their tort suits before plaintiff-friendly courts. One theory—that a corporation consents to jurisdiction over any and all claims when it registers to do business in a State—has been accepted in only one State: Pennsylvania.

But now even Pennsylvania appears ready to reject consent jurisdiction. The Superior Court of Pennsylvania (the State’s intermediate appellate court) in December agreed to rehear the issue en banc after issuing several decisions in recent years that endorsed consent jurisdiction. And earlier this month, a federal district judge in Philadelphia broke ranks with his colleagues and held, in Sullivan v. A.W. Chesterton, Inc., that consent jurisdiction is inconsistent with the requirements of the Due Process Clause. While conceding that a 1991 U.S. Court of Appeals for the Third Circuit decision, Bane v. Netlink, Inc., endorsed consent jurisdiction over any nonresident business that registers to do business in Pennsylvania, Sullivan concluded that “Daimler effectively disassembled the legal scaffolding upon which Bane was based.”