February 19, 2016

Helicopteros Nacionales de Colombia, S.A. v. Hall | Case Brief - 466 U.S. 408, 104 S.Ct. 1868 (1984) - US Supreme Court

FACTS: Helicol is a Columbian corporation with its principal place of business in Bogota.  On January 26, 1976 one of its helicopters crashed and killed 4 US citizens.  The 4 US citizens had been employed by a Houston based venture called Consorcio/WSH.  Consorcio/WSH drew up a contract with Helicol to stating that the official residence of the parties would be considered Lima, Peru and all matters would be resolved in Peruvian Courts.  Consorcio/WSH would also make payment to the Helicol bank account in NY.  Helicol sent personnel to Bell Coptor in Ft. Worth for training and to get helicopters.  They received $5 mil in the NY bank account as well.  Beyond that Helicol has had no other business contacts within the state of TX. 

HISTORY: Respondents instituted wrongful death actions in the district court of Harris county, TX against Consorcium/WSH, Bell Helicoptor, and Helicol.  Consolidated jury trail awarded $1 mil+ to respondents.  TX Court of Appeals reversed saying in personam jurisdiction was lacking. TX Supreme Court reversed.

ISSUE: Was it consistent with the Due Process Clause for Texas courts to assert in personam jurisdiction over Helicol?

HOLDING: No

RATIONALE: One-trip by Helicol CEO does not seem to be of a "continuous and systematic" nature.  Checks for the bank account were never requested by Helicol to be drawn on TX accounts.  This can be considered as unilateral activity.  Purchases and related trips are not sufficient to justify "minimum contact."

DISSENT: "The court may be placing severe limitations on the type and amount of contacts that will satisfy the constitutional minimum." (239)

Helicol has purposefully availed itself to the obligations and benefits of the forum of TX.  Its activities are in line with the cause of action initiated here and do not offend traditional notions of fair play and substantial justice under the Due Process Clause. (239)