## Facts

- Thomas F. Dooley, a former Sikorsky/United Technologies employee, sued United Technologies/Sikorsky entities, foreign companies, and individuals.
- Dooley alleged an international scheme to secure Saudi helicopter sales through illicit payments, including laundering funds and bribing foreign officials.
- The alleged scheme related to a 1986 agreement by the Saudi Ministry of Defense and Aviation to purchase helicopters, including Black Hawks.
- Dooley alleged the foreign defendants helped structure and route payments through the United States, including use of a Washington, D.C.–based intermediary (Basil, Inc.), and participated in communications and transactions connected to D.C.
- The complaint asserted civil RICO claims based on alleged predicate acts including mail and wire fraud and conduct tied to statutes governing corruption, money laundering, and arms exports.
- Dooley alleged he suffered injury to business/property from the scheme and related retaliation after he discovered or challenged the conduct during his employment.
- British defendants (Westland entities) and Saudi defendants (Al Namlah and Thimar entities) moved to dismiss under Rule 12 for lack of personal jurisdiction and failure to state a RICO claim; certain state-law claims were also challenged.

## Issues

1. Whether the court could exercise specific personal jurisdiction over the British and Saudi defendants under the D.C. long-arm statute and due process based on alleged D.C.-connected acts in furtherance of the scheme.
2. Whether the complaint plausibly stated civil RICO claims against the foreign defendants, including an enterprise, participation in the enterprise’s affairs, a pattern of racketeering activity, and injury by reason of the racketeering.
3. Whether supplemental state-law claims against the foreign defendants should be dismissed at the pleading stage.

## Decision

- The court denied the British and Saudi defendants’ motions to dismiss the core RICO claims.
- The court held personal jurisdiction existed because the complaint alleged purposeful, forum-related conduct tied to the alleged scheme, and exercising jurisdiction comported with due process.
- The court held the complaint sufficiently pleaded RICO elements at the Rule 12 stage, including an enterprise, participation, and a pattern of predicate acts (including mail and wire fraud).
- The court dismissed certain non-RICO state-law claims against the foreign defendants but allowed the main federal RICO claims to proceed.

## Legal Principles

- Specific personal jurisdiction may be exercised over foreign defendants when the complaint alleges purposeful forum-directed conduct and the claims arise out of or relate to that conduct, consistent with “minimum contacts” and fair play and substantial justice.
- At the motion-to-dismiss stage, the court accepts well-pleaded factual allegations as true and assesses whether they plausibly state each element of a civil RICO claim.
- A civil RICO complaint may proceed where it plausibly alleges (i) an enterprise, (ii) defendants’ conduct or participation in the enterprise’s affairs, (iii) a pattern of racketeering activity supported by predicate acts such as mail and wire fraud, and (iv) injury to business or property by reason of the racketeering.
- Supplemental state-law claims may be dismissed where inadequately pleaded or otherwise defective even when federal claims remain pending.

## Conclusion

The court allowed civil RICO claims to proceed against British and Saudi defendants alleged to have participated in an international bribery and payment-laundering scheme connected to Washington, D.C., finding both personal jurisdiction and adequate RICO pleadings, while trimming certain non-RICO state-law claims.


Dooley v. United Techs. Corp., 803 F. Supp. 428 (D.D.C. 1992)