Petroleum Helicopters, Inc. v. Avco Corp.
513 So.2d 1188, 1987 La. LEXIS 10227 (1987)
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Rule of Law:
An amendment to a state's long-arm statute that expands personal jurisdiction to the full extent permitted by constitutional due process is considered procedural and applies retroactively to cases pending at the time of its enactment.
Facts:
- A California corporation manufactured emergency floatation devices.
- A Texas company purchased these devices and installed them on a helicopter it built.
- Petroleum Helicopters, Inc., a Louisiana corporation, purchased this helicopter from the Texas company.
- The California manufacturer conducted substantial business in Louisiana, generating over $1.7 million per year and sending representatives to the state monthly.
- However, the specific flotation devices involved in the incident were never sold or supplied directly to any entity in Louisiana by the California manufacturer.
- The helicopter owned by Petroleum Helicopters, Inc. sank in the Gulf of Mexico outside of Louisiana's territorial waters, allegedly due to the failure of the floatation devices.
Procedural Posture:
- Petroleum Helicopters, Inc. filed suit against the California manufacturer and others in the U.S. District Court for the Western District of Louisiana.
- The manufacturer moved to dismiss the action for lack of personal jurisdiction.
- The district court granted the manufacturer's motion to dismiss.
- Petroleum Helicopters, Inc. (appellant) appealed the dismissal to the U.S. Court of Appeals for the Fifth Circuit.
- The Fifth Circuit determined that exercising jurisdiction over the manufacturer would not violate constitutional due process but was uncertain if the state statute authorized it.
- The Fifth Circuit certified the question of the scope of the Louisiana Long-arm Statute to the Supreme Court of Louisiana.
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Issue:
Does a legislative amendment expanding a state's long-arm statute to the full limits of constitutional due process apply retroactively to a pending lawsuit?
Opinions:
Majority - Justice Lemmon
Yes, a legislative amendment that expands a state's long-arm statute to the limits of due process applies retroactively. The court determined that the original question certified by the Fifth Circuit—whether the pre-amendment statute conferred jurisdiction—was rendered moot by the 1987 amendment to Louisiana's Long-arm Statute, La.R.S. 13:3201(B). This amendment expressly extends the jurisdictional reach of Louisiana courts to any basis consistent with the state and federal constitutions, making the limits of the statute and due process coextensive. The court characterized long-arm statutes as procedural, not substantive, and held that procedural laws are presumed to apply retroactively. Because the Fifth Circuit had already concluded that exercising jurisdiction over the manufacturer satisfied constitutional due process, the newly amended and retroactively applied state statute therefore also authorizes jurisdiction.
Analysis:
This decision significantly simplifies the personal jurisdiction analysis in Louisiana, collapsing the previous two-step inquiry (statutory authorization and constitutional compliance) into a single constitutional due process analysis. It establishes that Louisiana's legislative intent is to exercise jurisdiction to the fullest extent permissible under the Fourteenth Amendment. The ruling on retroactivity reinforces the characterization of long-arm statutes as procedural, impacting pending litigation by potentially subjecting defendants to jurisdiction where it might not have previously existed under the statute's literal text.
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