Insurance Corp. of Ireland, LTD. v. Compagnie Des Bauxites de Guinee

Citation. 456 U.S. 694 (1982)

Brief Fact Summary.

Respondent sued Petitioner over an insurance dispute. Petitioner argued the court lacked personal jurisdiction. Respondent tried to prove personal jurisdiction through Petitioner’s contacts with the state, but Petitioner refused to comply with the discovery order.

Synopsis of Rule of Law.

It does not offend traditional notions of fair play and substantial justice to sanction a defendant for disobeying a court order in support of establishing personal jurisdiction.

Compagnie des Bauxites de Guinee (Respondent) brought a lawsuit in a Pennsylvania federal court to collect on its business interruption insurance. Insurance Corporation of Ireland (Petitioner) moved for summary judgment, arguing that Pennsylvania lacked personal jurisdiction. In response, Respondent sought discovery of Petitioner’s contacts with Pennsylvania. Petitioner refused to provide the documents and Respondent filed a motion to compel the documents.

Issue.

Did the Pennsylvania court violate due process by sanctioning Petitioner when personal jurisdiction was in dispute?

Held.

No, the court did not violate due process.

Discussion.

The Court determined that it was not a violation of due process for the Pennsylvania court to establish personal jurisdiction by sanctioning the Petitioner. The Court noted that, contrary to Petitioner’s argument, personal jurisdiction could be waived and established like other rights, so long as it comported with traditional notions of fair play and substantial justice under the Due Process Clause. Here, there was no such violation because the sanction was proper. Petitioner was at least temporarily under Pennsylvania’s personal jurisdiction for purposes of resolving the dispute over jurisdiction, and the court could properly impose a sanction when Petitioner refused to comply with a court order.