Facts
- Helicopteros Nacionales de Colombia, S.A. (Helicol), a Colombian corporation, provided helicopter transportation services in South America.
- Helicol had no place of business in Texas, was not licensed there, and did not operate helicopters in Texas.
- A Houston-based joint venture (through a Peruvian consortium) contracted with Helicol for helicopter services to be performed in Peru.
- Helicol’s forum contacts included: a single trip by its CEO to Houston to negotiate the contract; receipt of payments via checks drawn on a Texas bank (deposited in New York); substantial purchases of helicopters and equipment from a Texas manufacturer; and sending personnel to Texas for training with that manufacturer.
- The contract stated the parties were residents of Peru and provided that controversies arising from the contract would be submitted to Peruvian courts.
- A Helicol helicopter crashed in Peru, killing several employees connected to the pipeline project; the accident and alleged negligence occurred in Peru.
- Representatives of the decedents filed wrongful death actions in Texas state court; Helicol contested personal jurisdiction.
- The Texas trial court exercised jurisdiction and entered judgment for plaintiffs; an intermediate appellate court reversed for lack of jurisdiction; the Texas Supreme Court reinstated jurisdiction; the U.S. Supreme Court reversed.
Issues
- Whether Texas courts could assert general in personam jurisdiction over a foreign corporation when the claims did not arise out of or relate to the corporation’s Texas contacts.
- Whether contract negotiations in Texas, payments drawn on a Texas bank, and substantial purchases and training trips to Texas constitute “continuous and systematic” contacts sufficient for general jurisdiction under the Due Process Clause.
Decision
- The Court held Texas could not exercise general personal jurisdiction over Helicol on claims unrelated to Helicol’s Texas activities.
- Because the accident and alleged tortious conduct occurred in Peru and the services were performed there, the case did not involve specific jurisdiction.
- A single contract-negotiation visit to Texas was not a continuous and systematic contact.
- Receiving payment by checks drawn on a Texas bank and deposited elsewhere was of minimal significance for general-jurisdiction purposes.
- Substantial purchases of goods and related training in Texas, even if occurring at regular intervals, were insufficient—without more—to establish the continuous and systematic contacts required for general jurisdiction.
- The Texas Supreme Court’s assertion of jurisdiction violated the Due Process Clause of the Fourteenth Amendment.
Legal Principles
- Specific jurisdiction applies when the cause of action arises out of or relates to the defendant’s forum contacts; general jurisdiction permits suit on unrelated claims only when forum contacts are continuous and systematic.
- For general jurisdiction, “minimum contacts” requires contacts so continuous and systematic that asserting jurisdiction is consistent with traditional notions of fair play and substantial justice.
- Mere purchases in the forum, even if regular and substantial, do not by themselves support general in personam jurisdiction over a nonresident corporation in litigation unrelated to those transactions.
- Ancillary activities tied to purchasing (such as training associated with the vendor relationship) do not necessarily convert a purchasing relationship into continuous and systematic forum activity sufficient for general jurisdiction.
Conclusion
The Court rejected Texas’s exercise of general personal jurisdiction over a foreign corporation where the underlying tort occurred abroad and the defendant’s Texas connections were limited to a single negotiation trip, payment mechanics involving a Texas bank, and substantial purchases and related training, none of which amounted to continuous and systematic contacts.