## Facts

- Submersible Systems, Inc. (SSI), a Louisiana corporation, supplied remotely operated submersible vehicles and related equipment to Quantum Ingenieros, S.A. de C.V. (Quantum) for offshore pipeline inspection in Mexican waters.
- Perforadora Central, S.A. de C.V. (Central), a Mexican corporation, provided the vessel M/V DON FRANCISCO under a separate arrangement with Quantum and transported SSI’s equipment from Louisiana to Mexico.
- Quantum fell behind on payments owed to both SSI and Central; Central twice interrupted performance to pressure Quantum to pay.
- On June 23, 1997, Quantum and Central terminated the vessel charter, and the vessel returned to Dos Bocas, Mexico, with SSI employees and SSI-marked equipment aboard.
- The captain informed SSI’s employees that SSI’s equipment had been seized to force Quantum to pay Central; a Central agent reported SSI’s employees to Mexican immigration authorities over documentation issues.
- Central refused to release the equipment and pursued proceedings in Mexico asserting the equipment belonged to Quantum, not SSI.
- SSI alleged that while retained in the Mexican port the equipment was exposed to the elements, became unusable, and caused significant economic loss.

## Issues

1. Whether Mississippi’s long-arm statute’s tort prong permitted jurisdiction over Central when the alleged conversion occurred in Mexico.
2. Whether Central’s Mississippi activities (rig construction in Mississippi and a small supervisory office) constituted “doing business” or otherwise supported general jurisdiction for this dispute.
3. Whether exercising jurisdiction over Central would satisfy due process minimum-contacts requirements when the claim arose from conduct and events in Mexico.

## Decision

- The Fifth Circuit held the district court lacked personal jurisdiction over Central.
- The court concluded the Mississippi long-arm statute did not reach the claim because the alleged tort was committed solely in Mexico.
- The court further held Central’s Mississippi contacts, tied to a discrete rig-construction project, were insufficient for general jurisdiction and unrelated to the conversion claim for specific jurisdiction.
- The court vacated the judgment (including over $4.25 million in compensatory and punitive damages) and remanded with instructions to dismiss for lack of jurisdiction.
- Because jurisdiction was dispositive, the court did not reach the merits or damages issues.

## Legal Principles

- Personal jurisdiction in federal court requires both authorization under the forum state long-arm statute and compliance with federal due process.
- Mississippi’s tort long-arm prong does not confer jurisdiction where the alleged tortious conduct and injury-causing events occurred wholly outside Mississippi.
- Specific jurisdiction requires a nexus between the defendant’s forum contacts and the plaintiff’s cause of action; unrelated forum contacts do not support jurisdiction.
- General jurisdiction requires continuous and systematic forum contacts; limited, project-specific activity (including maintaining a small office to supervise a single construction project) is ordinarily insufficient.
- When operative facts are centered abroad and the forum’s connection to the dispute is unrelated and fortuitous, asserting jurisdiction fails minimum-contacts and fairness requirements.

## Conclusion

The Fifth Circuit ordered dismissal because Central’s alleged conversion occurred in Mexico and its limited Mississippi presence for a separate construction project did not create either specific or general personal jurisdiction consistent with Mississippi’s long-arm statute and due process.


Submersible Sys., Inc. v. Perforadora Cent., S.A. de C.V., 249 F.3d 413 (5th Cir. 2001)