Helicopteros Nacionales de Colombia, S.A. v. Hall
(1984)
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Rule of Law:
A foreign corporation's regular purchases of goods and services from a forum state, even when coupled with related training trips and a single contract negotiation session, do not constitute the continuous and systematic contacts required by the Due Process Clause to establish general personal jurisdiction over a cause of action that does not arise out of or relate to those contacts.
Facts:
- Helicopteros Nacionales de Colombia, S.A. (Helicol), a Colombian corporation, provided helicopter transportation for oil and construction companies in South America.
- The decedents, four U.S. citizens, were employed by a Peruvian consortium (Consorcio/WSH), whose joint venture headquarters was in Houston, Texas, to work on a pipeline project in Peru.
- In 1974, Helicol's chief executive officer traveled to Houston, Texas, to negotiate a contract to provide helicopter services to Consorcio/WSH for the Peruvian pipeline project; the contract was ultimately signed in Peru.
- The contract specified that Consorcio/WSH would make payments to Helicol's New York bank account from its account at the First City National Bank of Houston.
- Between 1970 and 1977, Helicol purchased approximately 80% of its helicopter fleet, spare parts, and accessories for over $4 million from Bell Helicopter Company in Fort Worth, Texas.
- During that same period, Helicol sent its pilots to Fort Worth for training and its management personnel for technical consultations at Bell's facilities.
- On January 26, 1976, a helicopter owned and operated by Helicol crashed in Peru, killing the four U.S. citizens.
- Helicol was never authorized to do business in Texas, had no agent for service of process, performed no helicopter operations, solicited no business, signed no contracts, and owned no property in Texas.
Procedural Posture:
- The survivors and representatives of the decedents filed wrongful-death actions against Helicol in the District Court of Harris County, Texas, a state trial court.
- Helicol made a special appearance and filed a motion to dismiss for lack of in personam jurisdiction, which the trial court denied.
- After a jury trial, a judgment of over $1.1 million was entered against Helicol.
- Helicol, as appellant, appealed to the Texas Court of Civil Appeals, an intermediate appellate court.
- The Court of Civil Appeals reversed the trial court's judgment, holding that Texas lacked personal jurisdiction over Helicol.
- The decedents' representatives, as appellants, appealed to the Supreme Court of Texas, the state's highest court.
- The Supreme Court of Texas initially affirmed the intermediate appellate court but, upon rehearing, reversed its own decision and held that jurisdiction was proper.
- The U.S. Supreme Court granted Helicol's petition for a writ of certiorari.
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Issue:
Does a foreign corporation's purchases of helicopters and related training in a forum state, along with a single contract negotiation session there, constitute the continuous and systematic contacts required by the Due Process Clause to permit a court in that state to exercise general personal jurisdiction over a cause of action unrelated to those contacts?
Opinions:
Majority - Justice Blackmun
No. Helicol's contacts with Texas were insufficient to permit a Texas court to assert general personal jurisdiction over it. The Due Process Clause allows general jurisdiction over a non-resident defendant for claims not arising from its forum contacts only when those contacts are 'continuous and systematic.' Helicol’s single negotiation trip to Houston was not continuous, and its acceptance of checks drawn on a Houston bank was a unilateral act of another party, not a purposeful contact by Helicol. Citing Rosenberg Bros. & Co. v. Curtis Brown Co., the Court held that 'mere purchases, even if occurring at regular intervals, are not enough to warrant a State’s assertion of in personam jurisdiction' for an unrelated cause of action. The related training trips for Helicol's personnel were considered part of the purchase package and did not significantly enhance Helicol's contacts with Texas.
Dissenting - Justice Brennan
Yes. Helicol's contacts with Texas were sufficient to support the assertion of personal jurisdiction. The majority improperly relies on the outdated Rosenberg precedent and fails to recognize the evolution of jurisdictional standards in a modern national economy. More importantly, the Court incorrectly framed this as solely a general jurisdiction case. The wrongful-death claim is significantly 'related to' Helicol’s Texas contacts: the contract for the helicopter services was negotiated in Texas, the helicopter involved in the crash was purchased in Texas, and the pilot was trained in Texas. These related contacts make it fair and reasonable under the Due Process Clause for the Texas courts to exercise specific jurisdiction over this particular action.
Analysis:
This case significantly clarifies and narrows the scope of general personal jurisdiction over foreign corporations. It establishes that substantial, ongoing commercial transactions like purchasing goods, without more, are not enough to render a corporation 'at home' in the forum state for suits unrelated to those transactions. The decision reinforces the high threshold for general jurisdiction, distinguishing it sharply from specific jurisdiction, and reaffirms the precedent set in Rosenberg. By declining to find jurisdiction, the Court signaled a cautious approach to expanding jurisdictional reach based solely on a globalized supply chain, impacting how future plaintiffs may sue foreign entities in U.S. courts for events occurring abroad.
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