Friday, December 27, 2013

Helicopteros Nacionales de Columbia, S.A. v. Hall case brief

Helicopteros Nacionales de Columbia, S.A. v. Hall case brief summary
466 U.S. 408 (1984)

Petitioner foreign corporation sought review of a decision of the Supreme Court of Texas, which ruled that the corporation's contacts with the state were sufficient to allow a state court to assert jurisdiction over the corporation in respondent representatives' cause of action against the corporation for the wrongful deaths of their decedents, which did not arise out of, and was unrelated to, the corporation's activities within the state.

The foreign corporation entered into contract negotiations in Texas with decedents' employer to provide helicopter services. They signed a contract in Peru that provided for decedents' employer to make payments to the corporation's United States bank account. The corporation did not maintain a place of business in Texas, but purchased helicopter parts there and sent employees there for training. The decedents' representatives filed a wrongful death action against the corporation following the decedents' deaths in a helicopter crash in Peru.


  • Reversing the lower court, the Supreme Court held that the corporation's contacts with the state were not sufficient to subject it to the state court's in personam jurisdiction. 
  • Because the representatives' causes of action for wrongful death arose out of the crash in Peru, and were not related to the corporation's contacts with the state, and the corporation's business contacts with the state were not continuous and systematic enough to satisfy the requirements of the Due Process Clause of the Fourteenth Amendment, the Supreme Court concluded that the state court lacked personal jurisdiction over the corporation.
The Supreme Court reversed the state court's judgment that found the corporation subject to the in personam jurisdiction of the state courts.

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1 comment:

  1. Helicopteros Nacionales de Colombia, S.A. v Hall limit to general personal jurisdiction

    § Helicol, Colombian corporation, appeals plaintiff’s establishing jurisdiction over him after a plane crash. Court had to establish that Helicol had contacts within Texas for it to be fair to render a judgment against him (president made one trip to Texas, purchased helicopters there, and sent pilots to train there)

    § 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 case of action not related to those transactions.

    § Distinguishable from Perkins where contacts were substantial and continuous.


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