## Facts

- Maryland residents Vijai Rao and Sumathi Mathur traveled to Alaska and purchased tickets for an Era Alaska Airlines flight from Kodiak to Anchorage using Expedia.com while in Maryland.
- Era was an Alaska-based airline providing intrastate service only within Alaska and did not operate flights, maintain offices, or employ personnel in Maryland.
- Era’s flights were available for purchase through Expedia via Sabre, a global distribution system used by Era; Sabre maintained an office in Maryland.
- On August 22, 2010, after the Kodiak-to-Anchorage flight, plaintiffs discovered a case containing jewelry and cash was missing.
- Plaintiffs alleged Era personnel communicated about recovering the property at the Kodiak airport but the case was not returned.
- Plaintiffs sued Era and its president, Bob Hadjukovich (an Alaska resident), in the U.S. District Court for the District of Maryland asserting tort claims stemming from the loss.

## Issues

1. Whether Maryland’s long-arm statute and due process permit specific personal jurisdiction over an Alaska-only airline based on Maryland residents’ online purchase of tickets for an intrastate Alaska flight through Expedia/Sabre.
2. Whether use of third-party internet intermediaries (global distribution systems and travel websites), including an intermediary with a Maryland office, constitutes purposeful availment or purposeful direction toward Maryland.
3. Whether Maryland may exercise personal jurisdiction over the airline’s Alaska-resident president absent independent forum-directed contacts related to the claims.

## Decision

- The court granted defendants’ renewed motion to dismiss for lack of personal jurisdiction.
- The court held Maryland could not exercise specific personal jurisdiction over Era because plaintiffs’ claims arose from an intrastate Alaska flight and Era did not purposefully direct business activity to Maryland.
- The court held the Expedia/Sabre booking pathway, including Sabre’s Maryland presence, was too attenuated to establish Era’s forum-directed contacts.
- The court held Maryland likewise lacked personal jurisdiction over Hadjukovich because there was no showing of his personal, claim-related contacts with Maryland.
- The court treated plaintiffs’ proposed jurisdictional amendments as futile because the added facts did not cure the absence of constitutionally sufficient contacts.

## Legal Principles

- Specific personal jurisdiction requires (1) authorization under the forum’s long-arm statute and (2) minimum contacts consistent with due process.
- A defendant must purposefully avail itself of the forum or purposefully direct activity into the forum; the plaintiff’s unilateral activity cannot create jurisdiction.
- In internet-related commerce, globally accessible booking or advertising through third-party platforms, without evidence of deliberate forum targeting or manifest intent to do business in the forum, is insufficient for specific jurisdiction.
- Contacts of independent intermediaries are not attributed to a defendant absent a basis to treat the intermediary’s forum activities as the defendant’s own forum-directed conduct.
- Personal jurisdiction over an individual officer requires an independent, claim-related jurisdictional basis tied to the officer’s own contacts with the forum.

## Conclusion

The court dismissed the Maryland action because an Alaska-only airline and its president lacked Maryland-directed minimum contacts; online ticket sales to Maryland residents through third-party booking systems did not show deliberate forum targeting or support specific personal jurisdiction.


Rao v. Era Alaska Airlines, 22 F. Supp. 3d 529 (D. Md. 2014)