## Facts

- Eleanor Bryant, a New York resident, was injured in Paris while working for Trans World Airlines when a baggage cart was blown into her by jet blast from an aircraft operated by Finnish National Airline.
- The alleged negligence and injury occurred entirely in France.
- Finnish National Airline was a Finnish corporation headquartered in Helsinki, not registered to do business in the United States, and it operated no flights to or from the United States.
- The airline maintained a New York City office with several employees performing ongoing tasks: transmitting reservation requests for European travel, and providing information, publicity, and public-relations services.
- The New York personnel did not sell tickets, could not finalize reservations, and lacked authority to bind the airline; contracts required approval in Finland.
- The New York office maintained a small local bank account used to pay operating expenses.
- Bryant sued the airline in New York, invoking New York’s general jurisdiction doctrine for corporations doing business in the state and a statute permitting residents to sue foreign corporations “for any cause of action.”

## Issues

1. Whether the airline’s New York office activities constituted “doing business” in New York sufficient for personal jurisdiction under CPLR 301.
2. Whether, if the airline was doing business in New York, a New York resident could maintain an action in New York for a tort occurring abroad under former General Corporation Law § 224.

## Decision

- The Court of Appeals reversed the Appellate Division and reinstated the order denying the motion to dismiss for lack of personal jurisdiction.
- The court held the airline’s continuous New York operations were sufficient to constitute doing business in New York for jurisdictional purposes.
- The court held that, once doing business was established, the resident-plaintiff statute permitted suit in New York for a cause of action arising outside the state.

## Legal Principles

- Under CPLR 301, a foreign corporation is subject to New York jurisdiction when its in-state activities are continuous, systematic, and regular enough to constitute doing business.
- The doing-business inquiry focuses on the practical, ongoing corporate presence in New York, not solely on formal indicia such as authorization to bind contracts, ticket sales authority, or whether the company’s core service physically operates in the state.
- When a foreign corporation is doing business in New York, a statute permitting residents to sue foreign corporations “for any cause of action” allows a New York resident to sue in New York even for an out-of-state tort.

## Conclusion

The court held that the airline’s sustained New York office operations supporting reservations and promotion constituted doing business, allowing New York courts to exercise personal jurisdiction and permitting a New York resident to sue for an injury suffered abroad.


Bryant v. Finnish Nat'l Airline, 15 N.Y.2d 426, 260 N.Y.S.2d 625, 208 N.E.2d 439 (N.Y. 1965)