Professional Documents
Culture Documents
Hall,
ER:
Facts
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 certiorari.
Issue
• 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?
Ruling:
• 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. – Judgment reversed
Dissent (Brennan)
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.
D: Lack of residential or other contacts with forum state of itself does not
defeat otherwise proper jurisdiction.
Facts:
Issue: WON Texas has in personam jurisdiction over Helicol ? ( guys, I am not sure
dito, medyo malabo yung case…)
Held: Yes, respondents' lack of residential or other contacts with Texas of itself does
not defeat otherwise proper jurisdiction. The court is exercising general jurisdiction
over his person.
Ratio:
The lack of contacts shows nothing about the nature of the relationship between
respondents and Helicol, which could possibly enhance Helicol's contacts with
Texas. The harm suffered by respondents did not occur in Texas. Nor is it alleged
that any negligence on the part of Helicol took place in Texas.
The Due Process Clause of the Fourteenth Amendment operates to limit the power
of a State to assert in personam jurisdiction over a nonresident defendant. Due
process requirements are satisfied when in personam jurisdiction is asserted over a
nonresident corporate defendant that has “certain minimum contacts with [the forum]
such that the maintenance of the suit does not offend ‘traditional notions of fair play
and substantial justice.’ ”
When a controversy is related to or “arises out of” a defendant's contacts with the
forum, “relationship among the defendant, the forum, and the litigation” is the
essential foundation of in personam jurisdiction.
It has been said that when a State exercises personal jurisdiction over a defendant in
a suit arising out of or related to the defendant's contacts with the forum, the State is
exercising “specific jurisdiction” over the defendant.
Even when the cause of action does not arise out of or relate to the foreign
corporation's activities in the forum State, due process is not offended by a State's
subjecting the corporation to its in personam jurisdiction when there are sufficient
contacts between the State and the foreign corporation.
The court cites Perkins v. Benguet Consolidated Mining Co., where the Court
addressed a situation in which state courts had asserted general jurisdiction over a
defendant foreign corporation. In this case, the court held that a foreign corporation,
through its president, “ha[d] been carrying on in Ohio a continuous and systematic,
but limited, part of its general business,” and the exercise of general jurisdiction over
the Philippine corporation by an Ohio court was “reasonable and just.”
When a State exercises personal jurisdiction over a defendant in a suit not arising
out of or related to the defendant's contacts with the forum, the State has been said
to be exercising “general jurisdiction” over the defendant.
Issue: WON Helicol's contacts with the State of Texas constitute a continuous and
systematic general business contacts the Court found to exist in the Perkins case.
Held: No
Ratio:
Helicol did not have its principal place of office in Texas and was only sending
representatives to do business or transactions for operations in the said state.
TRIPS: The one trip to Houston by Helicol's chief executive officer for the purpose of
negotiating the transportation-services contract with Consorcio/WSH cannot be
described or regarded as a contact of a “continuous and systematic” nature, as
Perkins described it, and thus cannot support an assertion of in personam jurisdiction
over Helicol by a Texas court.
PURCHASES: The Texas Supreme Court focused on the purchases and the related
training trips in Rosenberg Bros. & Co. v. Curtis Brown Co., the court clarified that
purchases and related trips, standing alone, are not a sufficient basis for a State's
assertion of jurisdiction. The Court concluded: “Visits on such business, even if
occurring at regular intervals, would not warrant the inference that the corporation
was present within the jurisdiction of [New York].”
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 those purchase transactions. Nor can we conclude that
the fact that Helicol sent personnel into Texas for training in connection with the
purchase of helicopters and equipment in that State in any way enhanced the nature
of Helicol's contacts with Texas.
TRAINING: The training was a part of the package of goods and services purchased
by Helicol from Bell Helicopter. The brief presence of Helicol employees in Texas for
the purpose of attending the training sessions is no more a significant contact than
were the trips to New York made by the buyer for the retail store in Rosenberg.