Friday, December 6, 2013

Insurance Corp. of Ireland, Ltd. v. Compagnie Des Bauxites De Guinee case brief

Insurance Corp. of Ireland, Ltd. v. Compagnie Des Bauxites De Guinee case brief summary
456 U.S. 694 (1982)


CASE SYNOPSIS
The court granted certiorari when the United States Court of Appeals for the Third Circuit determined that the district court, finding under Fed. R. Civ. P. 37(b) that petitioners were subject to in personam jurisdiction in respondent's action seeking indemnification from petitioners, did not constitute an abuse of discretion.

CASE FACTS
Petitioners provided excess business interruption insurance to cover respondent's operations in a foreign country. Respondent allegedly experienced mechanical problems, resulting in a business interruption loss. Respondent brought suit when all of the insurers refused to indemnify respondent. When petitioners failed to produce documents requested by respondent during discovery, the district court assumed under Fed. R. Civ. P. 37(b) that petitioners were subject to in personam jurisdiction due to their business contacts with the state.

DISCUSSION
  • The court found that application of a legal presumption to the issue of personal jurisdiction did not in itself violate the Due Process Clause. 
  • The court held that application of the sanction was just under the circumstances because petitioners failed to comply with several court orders despite warnings of sanctions, and that the sanction was specifically related to the particular claim at issue in the order to provide discovery because respondent was seeking through discovery to respond to petitioners' contention that the district court lacked jurisdiction. 
  • Therefore, the court found that the district court did not abuse its discretion.
CONCLUSION
The court affirmed and held that the district court did not abuse its discretion in finding that petitioners were subject to personal jurisdiction under the applicable sanction.


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