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Helicopteros Nacionales de Colombia v. Hall

Supreme Court of the United States · 1984 · Civil Procedure

Civil Procedurepersonal jurisdictiongeneral jurisdictioncontinuous and systematic contactspersonal jurisdictiongeneral jurisdictionminimum contactscontinuous and systematic

Facts

Helicol was a Colombian corporation with its principal place of business in Bogota, and its helicopter crashed in Peru, killing four United States citizens employed on a Peru pipeline project. The claims did not arise out of or relate to any activity Helicol conducted in Texas. Helicol's Texas contacts consisted of one trip by its chief executive officer to Houston to discuss a transportation-services contract, acceptance of checks drawn on a Houston bank into its New York account, purchases of helicopters, parts, and accessories from a Fort Worth company totaling more than $4 million, and trips by personnel to Texas for training and consultation related to those purchases. Helicol had no office, place of business, license, property, employees based in Texas, agent for service, solicitation, operations, or other business contacts in Texas.

Issue

Whether Texas courts could, consistent with the Due Process Clause, exercise general personal jurisdiction over Helicol in a suit that concededly did not arise out of or relate to Helicol's activities in Texas. More specifically, the question was whether Helicol's Texas contacts were sufficiently continuous and systematic to support general jurisdiction.

Rule

When a cause of action does not arise out of or relate to a foreign corporation's activities in the forum State, due process permits personal jurisdiction only if the corporation has continuous and systematic general business contacts with the forum. Mere purchases in the forum, even if occurring at regular intervals, and related training trips, standing alone, are not enough to support general jurisdiction; nor is unilateral activity by another party, such as drawing checks on a forum bank, an appropriate basis for finding sufficient contacts.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Andes Lift S.A., a Chilean cargo company based in Santiago, is sued in Colorado over a crash in Argentina involving one of its aircraft. The plaintiffs concede the claim does not arise out of or relate to Colorado. For six years, Andes Lift bought replacement engines and avionics from a Denver supplier several times each year, totaling $6 million, but had no office, property, employees, or operations in Colorado.

May a Colorado court, consistent with due process, exercise general personal jurisdiction over Andes Lift based on these facts?

Explanation. When the cause of action does not arise out of or relate to the defendant's forum activities, the forum may assert jurisdiction only if the defendant has continuous and systematic general business contacts there. The majority held that mere purchases in the forum, even at regular intervals and for substantial sums, do not suffice standing alone. Plaintiffs' residence does not control the analysis, and dollar volume alone does not transform purchases into general business operations. (Derived from Helicopteros Nacionales de Colombia v. Hall (1984).)