Helicopteros Nacionales De Columbia v. Hall Case Brief

Summary of Helicopteros Nacionales De Columbia v. Hall
466 U.S. 408 [1984]

Relevant Facts: Pet, a Colombian corporation, entered into a K 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. Pet 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 CEO to Houston to negotiate the K 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.

Legal Issue(s): Whether Colombian corporation’s contacts with Texas, which consisted of one trip to Texas by corporation’s chief executive officer for purpose of negotiating transportation services contract, acceptance of checks drawn on Texas bank, and purchases of helicopters and equipment from Texas manufacturer and related training trips, were insufficient to satisfy requirements of due process clause of the Fourteenth Amendment ?

Court’s Holding: Yes -insufficient

Procedure: Texas state court entered judgment against petitioner on a jury verdict in favor of respondents. Texas Court of Civil Appeals reversed, holding that in personam jurisdiction over petitioner was lacking; reversed by the Texas Supreme Court. Reversed.

Law or Rule(s): Due process requirements are satisfied when in personam jurisdiction is asserted over a nonresident corporate defendant that has certain minimum contacts with the forum such that the maintenance of the suit does not offend traditional notions of fair play and substantial justice.

Court Rationale: 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.

Plaintiff’s Argument: Numerous and frequent commercial transactions with Texas are continuous and systematic contacts.

Defendant’s Argument: There are no minimum contacts between Helicopteros and Texas which arise out of the action; and there are no continuous and systematic contacts.



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