Helicopteros Nactionales de Colombia, S.A. v. Hall

Brief Fact Summary

Helicopteros Nacionales de Colombia, S.A. (Helicol) (Defendant) argued the Texas courts lacked personal jurisdiction over it due to a lack of minimum contacts with the state.

Synopsis of Rule of Law

A defendant’s contacts with the forum state must constitute continuous and systematic general business contacts in order for the forum state to exercise personal jurisdiction over it.

Facts

Helicopteros Nacionales de Colombia, S.A. (Helicol) (Defendant), a Colombian corporation with a principal place of business in Bogota, owned a helicopter that crashed in Peru and killed several U.S. citizens.  The citizens were employees of a joint venture headquartered in Texas.  Hall (Plaintiff) and other heirs of the employees sued for wrongful death in Texas state court.  Defendant moved to dismiss, arguing the Texas court lacked personal jurisdiction over it.  The trial court denied the motion, and the jury found against Defendant.  The court of appeals reversed, holding that Defendant’s contacts with Texas, basically the attendance by a Helicol (Defendant) executive at one meeting in Houston and the purchasing of helicopters and parts in Ft. Worth, were not sufficient to constitute the minimum contacts required.  The Texas Supreme Court reversed, and Helicol (Defendant) appealed.

Issue

Does a defendant’s contacts with the forum state have to constitute continuous and systematic general business contacts in order for the forum state to allow for personal jurisdiction?

Held

(Blackmun, J.)  Yes.  A defendant’s contacts with the forum state must constitute continuous and systematic general business contacts in order for the forum state to exercise personal jurisdiction.  It has long been held that purchases and occasional trips to the forum will not, on its own, establish the requisite minimum contacts.  Therefore, because no further showing was made regarding the contacts, the Texas courts lacked personal jurisdiction.  Reversed.

Dissent

(Brennan, J.)  This case establishes sufficient contacts to support a finding of personal jurisdiction in the relationship between the contacts and the cause of action.

Discussion

The dissent points out that while the contacts involved may not support general personal jurisdiction, if the particular claim arises out of such contacts, jurisdiction over the claim may exist.  The purchases in Ft. Worth were arguably related to the wrongful death claim because they were purchases of helicopter parts, some of which may have been used in helicopter before the crash.