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

466 U.S. 408 (1984)

A 1984 United States Supreme Court’s seminal opinion in the area of civil procedure/personal jurisdiction in which the Court held that, the mere fact that the nonresident defendant made regular purchases in the forum state, was not sufficient to justify the forum state’s exercise of personal jurisdiction in a case not related to such purchases.

Reference Desk

American Express Intern. v. Mendez-Capellan, 889 F.2d 1175 (1st Cir. 1989)

In Helicopteros Nacionales v. Hall, 466 U.S. 408104 S.Ct. 186880 L.Ed.2d 404(1983), the Supreme Court reviewed the exercise of in personam jurisdiction over a defendant foreign corporation by the Texas state courts. The defendant corporation’s only contacts with Texas consisted of contract negotiations within the state, accepting checks drawn on a Texas bank, purchasing materials and services from a corporation located in Texas, and sending employees to Texas for training See id. at 416, 104 S.Ct. at 1873. The Supreme Court held that the defendant’s contacts, which were unrelated to the cause of action, “were insufficient to satisfy the requirements of the Due Process Clause of the Fourteenth Amendment.” Id. at 418-19, 104 S.Ct. at 1874.

Dalmau Rodriguez v. Hughes Aircraft Co., 781 F.2d 9 (1st Cir. 1986)

Helicopteros Nacionales De Colombia, S.A. v. Hall, 466 U.S. 408104 S.Ct. 186880 L.Ed.2d 404 (1984) is a variation on the main theme. It involved a foreign corporation that did business in Texas. In rejecting Texas’ claim of jurisdiction, the Court held “that mere purchases, even if occurring at regular intervals, are not enough to warrant a State’s assertion of in personam jurisdiction over a nonresident corporation in a cause of action not related to those purchase transactions.” Id. at 418, 104 S.Ct. at 1874 (footnote omitted). In doing so, it relied on Rosenberg Bros. Co. v. Curtis Brown Co., 260 U.S. 51643 S.Ct. 17067 L.Ed. 372 (1923), noting that “[t]his Court i International Shoe acknowledged and did not repudiate its holding in Rosenberg.” 466 U.S. at 418104 S.Ct. at 1874.

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