Helicopteros Nacionales v. Hall, 466 U.S. 408 (1984)
Making purchases, negotiating a contract, or training employees in a state does not render a party automatically subject to general personal jurisdiction there.
A Colombian company named Helicopteros sent employees and materials to Consorcio for a pipeline project in Peru. Some of its executives traveled to a meeting in Houston during contract negotiations with Consorcio, and Helicopteros bought spare parts from a helicopter company in Texas. Its other interactions with the state consisted of training employees in Fort Worth and drawing checks that it deposited in Texas banks.
When a fatal helicopter crash occurred in Peru, Hall brought a wrongful death claim in a Texas court and prevailed against Helicopteros. On appeal, the court found that Texas lacked jurisdiction over the defendant.
- Harry Andrew Blackmun (Author)
- Warren Earl Burger
- Byron Raymond White
- Thurgood Marshall
- William Hubbs Rehnquist
- John Paul Stevens
- Sandra Day O'Connor
The minimum contacts test does not apply when the dispute does not arise from those contacts with the forum. Instead, the appropriate type of jurisdiction would be general jurisdiction, which requires systematic and continuous contacts between the defendant and the forum state. Since these activities were not continuous but focused on certain discrete projects, jurisdiction was not proper.
- William Joseph Brennan, Jr. (Author)
The minimum contacts test should have applied because the defendant's interactions with the forum state were related to the project in which the fatal crash occurred.Case Commentary
If a controversy is only peripherally related to a forum, the defendant's contacts must be proportionally more significant for jurisdiction to be proper.
U.S. Supreme CourtHelicopteros Nacionales v. Hall, 466 U.S. 408 (1984)
Helicopteros Nacionales de Columbia v. Hall
Argued November 8, 1983
Decided April 24, 1984
466 U.S. 408
Petitioner, a Colombian corporation, entered into a contract to provide helicopter transportation for a Peruvian consortium, the alter ego of a joint venture that had its headquarters in Houston, Tex., during the consortium's construction of a pipeline in Peru for a Peruvian state-owned oil company. Petitioner has no place of business in Texas, and never has been licensed to do business there. Its only contacts with the State consisted of sending its chief executive officer to Houston to negotiate the contract with the consortium, accepting into its New York bank account checks drawn by the consortium on a Texas bank, purchasing helicopters, equipment, and training services from a Texas manufacturer, and sending personnel to that manufacturer's facilities for training. After a helicopter owned by petitioner crashed in Peru, resulting in the death of respondents' decedents -- United States citizens who were employed by the consortium -- respondents instituted wrongful death actions in a Texas state court against the consortium, the Texas manufacturer, and petitioner. Denying petitioner's motion to dismiss the actions for lack of in personam jurisdiction over it, the trial court entered judgment against petitioner on a jury verdict in favor of respondents. The Texas Court of Civil Appeals reversed, holding that in personam jurisdiction over petitioner was lacking, but in turn was reversed by the Texas Supreme Court.
Held: Petitioner's contacts with Texas were insufficient to satisfy the requirements of the Due Process Clause of the Fourteenth Amendment, and hence to allow the Texas court to assert in personam jurisdiction over petitioner. The one trip to Houston by petitioner's chief executive officer for the purpose of negotiating the transportation services contract cannot be regarded as a contact of a "continuous and systematic" nature, and thus cannot support an assertion of general jurisdiction. Similarly, petitioner's acceptance of checks drawn on a Texas bank is of negligible significance for purposes of determining whether petitioner had sufficient contacts in Texas. Nor were petitioner's purchases of helicopters and equipment from the Texas manufacturer and the related training trips a sufficient basis for the Texas court's assertion of jurisdiction. Rosenberg Bros. & Co. v. Curtis Brown Co., 260 U. S. 516. 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. And the fact that petitioner sent personnel to Texas for training in connection with the purchases did not enhance the nature of petitioner's contacts with Texas. Pp. 466 U. S. 413-419.
638 S.W.2d 870, reversed.
BLACKMUN, J., delivered the opinion of the Court, in which BURGER, C.J., and WHITE, MARSHALL, POWELL, REHNQUIST STEVENS, and O'CONNOR, JJ., joined. BRENNAN, J., filed a dissenting opinion, post, p. 466 U. S. 419.