Helicopteros v. Hall

466 U.S. 408 (1984).


Facts: Helicopteros is a Colombian company that was operating in Peru providing transportation for a Peruvian counterpart to a U.S. company.  One of their helicopters crashed and four U.S. citizens were killed.  Their decedents sued Helicopteros (AKA Helicol), among others, for wrongful death in the state of Texas.


Procedural Posture: Helicol made a special appearance and argued that Texas state court did not have personal jurisdiction over the company.  The motion was denied by the trial court, and Helicol lost at trial.  They appealed on the basis of lack of personal jurisdiction, and the Texas Court of Civil Appeals reversed the judgment on that basis, while the Texas Supreme Court in turn reversed the ruling of the intermediate appellate court.  Helicol appealed to the United States Supreme Court.


Issue: Is it consistent with the Due Process Clause of the Fourteenth Amendment for Texas to assert personal jurisdiction over Helicol?


Rule: In order for the forum to exercise personal jurisdiction, the defendant must have “certain minimum contacts” that do not violate “fair play”.


Analysis: The Court cites two cases, Perkins and Rosenberg, to justify finding a lack of minimum contacts.  The Court argues that the present case is more like Rosenberg (where the only contacts were purchases and related trips) than Perkins (where Ohio courts were found to have jurisdiction over a Philippine corporation due to “continuous and systematic” contacts).


Brennan’s dissent uses the doctrine of purposeful availment to argue that there were indeed minimum contacts between the defendant and the forum.  Brennan disagrees with the court’s use of Rosenberg because he says it may be outdated given more recent decisions and advances in communications and transportation.


Brennan argues that the contacts between Helicol and Texas are significant because they show that Helicol received benefits from doing business in Texas, and thus should be on notice that they may face obligations there.


Brennan claims that the present case is distinguishable from both Perkins and Rosenberg in that the contacts are highly related to the claim.  Thus, the possibility of being sued in Texas should have been foreseeable to Helicol.


Finally, Brennan says that the Court in this decision limits specific jurisdiction too strictly.


Conclusion: The decision of the Texas Supreme Court was reversed, and it was found that Texas did not have jurisdiction.


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