## Facts

- On May 31, 2014, a Gulfstream G‑IV aircraft crashed during takeoff at Laurence G. Hanscom Field in Bedford, Massachusetts, killing all aboard, including passenger Lewis A. Katz.
- Drew Katz and Melissa Silver, as co-personal representatives of Katz’s estate, sued multiple defendants in Massachusetts and Georgia state courts, asserting wrongful-death and related tort and warranty theories connected to alleged defects in, and maintenance of, the aircraft’s interlock mechanism and gust-lock system.
- The Massachusetts case was removed to the U.S. District Court for the District of Massachusetts, where several defendants moved to dismiss under Fed. R. Civ. P. 12(b)(2) for lack of personal jurisdiction.
- Gulfstream Aerospace Corporation (Georgia) (“Gulfstream Georgia”) designed, manufactured, and sold the aircraft in Georgia and was not incorporated in Massachusetts, not registered to do business there, and did not maintain an in-state agent for service of process.
- Gulfstream Aerospace Corporation (Delaware) (“Gulfstream Delaware”) functioned as a holding company that owned Gulfstream Georgia and Gulfstream Aerospace Services Corporation (“Gulfstream Services”); it likewise was not incorporated in Massachusetts and did not have registration or an agent for service in Massachusetts.
- Gulfstream Services operated a Massachusetts facility and serviced the subject aircraft in January 2013 using technicians from that Massachusetts facility.
- Rockwell Collins, Inc. (“Rockwell”), a foreign corporation, designed, manufactured, and sold the interlock mechanism and gust-lock system outside Massachusetts and had not maintained a Massachusetts location since about 2005.
- Plaintiffs argued that the Massachusetts crash and the defendants’ connections to the Commonwealth supported jurisdiction, and they also argued that Gulfstream Services’ Massachusetts contacts should support jurisdiction over Gulfstream Georgia and Gulfstream Delaware.

## Issues

1. Whether Massachusetts could exercise general personal jurisdiction over Gulfstream Georgia, Gulfstream Delaware, Gulfstream Services, or Rockwell.
2. Whether Massachusetts could exercise specific personal jurisdiction over Gulfstream Georgia and Rockwell where the alleged design, manufacture, and sale occurred outside Massachusetts, but the crash occurred in Massachusetts.
3. Whether Gulfstream Services’ Massachusetts contacts could be attributed to Gulfstream Delaware (and/or Gulfstream Georgia) for jurisdiction purposes under an alter-ego or agency theory.
4. Whether Massachusetts could exercise specific personal jurisdiction over Gulfstream Services based on its in-state facility and its Massachusetts-based servicing of the aircraft before the crash.

## Decision

- The court granted the Rule 12(b)(2) motions and dismissed Gulfstream Georgia, Gulfstream Delaware, and Rockwell for lack of personal jurisdiction.
- The court denied Gulfstream Services’ Rule 12(b)(2) motion, holding plaintiffs made a prima facie showing of specific personal jurisdiction based on the Massachusetts-based maintenance work tied to the claims.

## Legal Principles

- When a court rules on a Rule 12(b)(2) motion without an evidentiary hearing, plaintiffs must make a prima facie showing that personal jurisdiction exists, using well-pled facts and competent proffers; conclusory allegations are not enough.
- A federal court sitting in diversity (or exercising supplemental jurisdiction over state-law claims) evaluates personal jurisdiction under the forum’s long-arm statute and the Due Process Clause.
- General jurisdiction over a corporation generally exists only where it is incorporated or has its principal place of business; other forums require an exceptional showing that the corporation is “at home” there.
- Specific jurisdiction requires: (1) relatedness between the claim and the defendant’s forum contacts, (2) purposeful availment (deliberate forum contacts making suit there foreseeable), and (3) reasonableness (often assessed through the Gestalt factors).
- For relatedness, the First Circuit requires a causal link between the forum conduct and the claim that falls between “but for” causation and proximate cause; the forum accident alone does not supply the necessary link to an out-of-state manufacturer’s out-of-state conduct.
- A parent’s or affiliate’s forum contacts are not automatically attributed across corporate lines; imputing contacts requires a developed showing (for example, alter-ego/veil-piercing or comparable agency facts) sufficient to disregard corporate separateness.
- Operating an in-state facility and performing in-state maintenance on the aircraft involved in the later accident can satisfy purposeful availment and relatedness at the prima facie stage where the alleged maintenance failures form part of the asserted causal chain.

## Conclusion

Katz v. Spiniello Cos. held that Massachusetts could not exercise personal jurisdiction over out-of-state entities whose alleged wrongful design, manufacturing, and holding-company conduct occurred elsewhere and was not tied to Massachusetts through forum-directed activity or a supported alter-ego/agency theory, but could exercise specific jurisdiction over the aircraft service company that operated a Massachusetts facility and performed Massachusetts-based maintenance alleged to be connected to the fatal crash.


Katz v. Spiniello Cos., 244 F. Supp. 3d 237 (2017)