Helicopteros Nacionales De Colombia, S.A. v. Hall
Helicopteros Nacionales de Colombia, S. A. v. Hall, 466 U.S. 408 (1984).
Parties: Helicopteros is a Colombian corporation. It provides helicopters to oil and construction companies in South America. Plaintiffs of original complaint are survivors and representatives of deceased.
Facts: A helicopter owned by Helicopteros crashed in Peru. Four US citizens were among those who died. The deceased were employees of Consorcio, a company that is the alter-ego of a joint venture of 3 US companies, called WSH. The venture was formed to bypass Peruvian laws that prevented anyone other than a Peruvian from working on oil pipe lines. The only connections that Helicopteros had with Texas were:
- when an executive flew to Houston to meet with WSH,
- when Helicopteros purchased their helicopters from Bell, a Texas company,
- when Bell trained helicopteros's pilots, and
- when Helicopteros sent management and maintenance personnel to visit Bell to receive "plant familiarization" and technical consultation.
Procedural History: Plaintiffs filed wrongful death actions in the District Ct. of Harris County, TX. Helicopteros filed special appearances and moved to dismiss for no jurisdiction. Motion denied. Ct. found for plaintiffs. Texas Ct. of Civil Appeals, Houston , First District, reversed. Texas Supreme Ct. initially affirmed appeal ct, but on a re-hearing decided withdrew initial decision and reversed, finding for plaintiffs.
Issue: Whether it was consistent with the Due Process Clause for Texas courts to assert in personam jurisdiction over Helicopteros.
Arguments: Helicopter purchases and related trips were sufficient to uphold jurisdiction.
Holding: Helicopteros's contacts with forum state were insufficient to assert jurisdiction.
Reasons: Just because the check to the defendants were drawn out of a Texas bank acct. into their NY account, that is not minimum contacts. The defendants had no control over it, nor did it matter to them from where the check is drafted. Purchases and related trips, standing alone, are not sufficient basis to uphold state's jurisdiction.
Comments: If jurisdiction were upheld, it would have been general jurisdiction, because the controversy that caused the complaint was not related to the actions which gave claim to the forum state to have jurisdiction. In dissent, Justice differentiates between controversies that "relate to" a defendant's contacts and one that "arises from" those contacts.