Helicopteros Nacionales de Colombia v. Hall – Case Brief Summary
Summary of Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408, 104 S.Ct. 1868, 80 L.Ed.2d 404 (1984).
Helicopteros Nacionales de Colombia (D), a Colombian corporation, purchased most of its helicopter fleet and obtained training for some of its pilots from a Texas manufacturer but had no place of business in Texas. Helicopteros contracted to provide helicopter transportation service for a Peruvian consortium, which was the alter ego of a joint venture headquartered in Houston. In the course of providing service under the contract, one of defendant’s helicopters crashed killing four American citizens on board.
Hall et al. (P) brought suit on behalf of the decedents in Texas state court against Helicopteros and other parties including Bell Helicopter, the Texas-based manufacturer of the helicopter. Helicopteros made a special appearance and moved to quash service for lack of personal jurisdiction on the grounds that it had very little contact with the state, and that its performance under the service contract involved no contact with the state. The trial court denied Helicopteros’s motion and the jury entered a verdict for Hall. The Texas Court of Appeals reversed, holding that the court did not have personal jurisdiction over Helicopteros. The Texas Supreme Court reinstated the trial court’s ruling and the jury award. The Supreme Court of the United States granted cert.
- How extensive must a party’s contacts with a forum state be in order for a court of that state to exercise general in personam jurisdiction over that party?
Holding and Rule (Blackmun)
- In order to exercise general in personam jurisdiction over a party, the party’s contacts with the forum state must be of a “continuous and systematic” nature.
The court held that the defendant’s contacts with Texas did not satisfy the requirements of the Due Process Clause, and the Texas court therefore could not assert in personam jurisdiction over the corporation.
The one trip to Houston by the defendant’s CEO for negotiating the transportation services contract and other activities unrelated to the cause of action were not contacts of a continuous and systematic nature and did not support an assertion of general jurisdiction. Nor did purchases of helicopters and training of its pilots from the Texas manufacturer form a sufficient basis for jurisdiction. Mere purchases, even if occurring at regular intervals, are not enough to warrant a State’s assertion of in personam jurisdiction over a nonresident corporation in a cause of action not related to the purchases.
Helicopteros purposefully availed itself of the benefits and obligations of the forum state. Active participants in interstate and foreign commerce take advantage of the economic benefits and opportunities offered by the various states. It is only fair and reasonable to subject to them to the obligations that may be imposed by those jurisdictions. Contacts with the forum state were sufficiently related to the underlying cause of action. The wrongful death claims assert the necessary requirements for specific jurisdiction because Helicopteros had contacts with Texas that were directly related to the negligence that Hall alleged in his complaint.
The cause of action in this case involved wrongful death claims based on negligence. There were no claims for breach of contract. Since the company’s CEO had negotiated the contract in Texas it is likely that the court would be able to exert in personam jurisdiction over the defendant for breach of contract claims. This case is also cited as Helicopteros v. Hall.
See Burger King Corp. v. Rudzewicz for a law school civil procedure case brief holding that a plaintiff need not show both that 1) a non-resident defendant has established minimum contacts with the state and 2) it is fair and equitable to hale the defendant into court to defend a lawsuit in that state.