Helicopteros v. Hall
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
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Brennan disagrees with the court’s use of Rosenberg because he says it may be outdated given more recent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
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.