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Helicopteros Nacionales de Colombia, S.A. v. Hall

From lawbrain.com

Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408, 104 S.Ct. 1868, 80 L.Ed.2d 404 (1984), is a civil procedure case where the U.S. Supreme Court held that in order to exercise personal jurisdiction over a party, the party’s contacts with the forum state must be of a "continuous and systematic" nature.

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Contents

Summary of Case Facts

Defendant, Helicopteros Nacionales de Colombia, a Colombian corporation, purchased most of its helicopter fleet and obtained training for some of its pilots from a Texas manufacturer, but had no place of business in Texas. Helicopteros contracted to provide helicopter transportation service for a Peruvian association, which was a joint venture headquartered in Houston, Texas. In the course of providing service under the contract, one of defendant’s helicopters crashed killing four American citizens on board. Plaintiff, Hall et al., brought suit on behalf of the decedents in Texas state court against Helicopteros. Helicopteros made a special appearance and moved to quash service for lack of personal jurisdiction on the grounds that it had very little contact with the state, and that its performance under the service contract involved no contact with the state.

Issue

Whether Texas has personal jurisdiction over the defendant.

Holding and Law

No. To exercise personal jurisdiction over a party, the party’s contacts with the forum state must be of a "continuous and systematic" nature. Mere purchases, even if occurring at regular intervals, are not enough to warrant a State’s assertion of personal jurisdiction over a nonresident corporation in a cause of action not related to the purchases.

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