Helicopteros Nacionales De Colombia, S.A. v. Hall

466 U.S. 408 (1984)

Facts

Helicopteros Nacionales de Colombia (D) was a Colombian corporation. D purchased about 80% of its helicopter fleet in Texas, and some of its pilots had been trained there, but D did not have any property or business offices in Texas. During a project with a Peruvian company, four U.S. citizens were killed in a helicopter crash in Peru. At the time of the crash, the decedents were employed by Consorcio (D1) and WSH (D2). D1 and D2 were a joint venture with headquarters in Houston, Texas. The joint venture rented the helicopter from D. The actual helicopter was manufactured by Bell Helicopter (D3) in Fort Worth, Texas. Hall's (P) decedent died in that crash. P sued D in Texas for wrongful death against all Ds. D filed a special appearance and moved to quash service for lack of personal jurisdiction. D stated its only contacts with Texas were sending it CEO to Texas to negotiate a rental contract, purchasing helicopters from D3, receiving training on helicopters from D3, and accepting and cashing checks from the D1-D2 joint venture drawn on a Houston bank. D’s motion was denied. The jury verdict went against D. The Texas Court of Appeals reversed the judgment holding that there was no in personam jurisdiction over D. The Texas Supreme court reinstated the trial court's ruling and the jury award of $1,141,200. The Supreme Court granted review.