## Facts

- Wrongful-death actions were filed by Illinois personal representatives of decedents killed in an airplane crash.
- Defendant Beech Aircraft Corporation was incorporated in Delaware with its principal place of business in Kansas.
- A co-defendant, Dixie Aviation Co., a South Carolina corporation, serviced the aircraft during a stop in Columbia, South Carolina.
- After departing South Carolina for Chicago, the aircraft crashed in Tennessee, killing all occupants.
- Plaintiffs sued in the U.S. District Court for the Eastern District of South Carolina, alleging negligent manufacture/design by Beech and negligent servicing by Dixie.
- Beech moved to quash service and dismiss for lack of jurisdiction, challenging service made through its South Carolina dealer as an “agent” under South Carolina law.

## Issues

1. Whether Beech’s South Carolina dealer could be treated as Beech’s “agent” for service of process under South Carolina law, consistent with due process, based on Beech’s contacts with the state.
2. Whether South Carolina’s “door-closing” statute limiting certain suits by nonresidents against foreign corporations in state court barred or restricted a federal district court’s diversity jurisdiction over Beech.

## Decision

- The Fourth Circuit affirmed the district court’s denial of Beech’s motion to quash service and dismiss.
- The court held service was valid because Beech’s control and supervision over its South Carolina dealer supported treating the dealer as Beech’s agent for service and showed sufficient contacts with South Carolina.
- The court held South Carolina’s door-closing statute did not limit the federal court’s diversity jurisdiction where statutory and constitutional diversity requirements were satisfied.

## Legal Principles

- A foreign corporation may be subject to service in a state through a local dealer treated as an “agent” when the corporation exercises substantial control and supervision over the dealer, and the relationship supplies sufficient forum contacts.
- State statutes restricting access to state courts for certain nonresident suits against foreign corporations do not, by themselves, curtail federal diversity jurisdiction conferred by federal law when diversity and amount-in-controversy requirements are met.
- In diversity cases, a federal court distinguishes between state rules that define substantive rights and state rules that primarily regulate use of state judicial forums; the latter do not necessarily bind the federal court’s jurisdictional exercise.

## Conclusion

The Fourth Circuit sustained personal jurisdiction and service on a foreign manufacturer through a controlled local dealer and refused to apply South Carolina’s door-closing statute to bar diversity suits in federal court where diversity jurisdiction otherwise existed.


Szantay v. Beech Aircraft Corp., 349 F.2d 60 (4th Cir. 1965)