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

In Helicopteros Nacionales De Colombia, S.A. v. Hall, 466 U.S. 408, 418, 80 L. Ed. 2d 404, 104 S. Ct. 1868 (1984), the United States Supreme Court examined a Colombian corporation's contacts with Texas to decide if Texas courts could exercise general jurisdiction. Helicopteros, 466 U.S. at 415-16. The nonresident defendant had purchased helicopters, equipment, and training services from a Texas company, sent its employees to Texas for training, and sent its chief executive officer to Houston for contract negotiation. Helicopteros, 466 U.S. at 416. The Supreme Court held that these contacts were insufficient to warrant a Texas court's exercising general jurisdiction. Helicopteros, 466 U.S. at 415-16 (reversing Hall v. Helicopteros, 638 S.W.2d 870 (Tex. 1982)). The Court noted 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." Helicopteros, 466 U.S. at 418. The United States Supreme Court stated 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." The Court in Helicopteros, analyzing facts somewhat similar to those presented here, concluded there was no basis for the assertion of personal jurisdiction. In that case, Helicol, a helicopter company from Colombia, contracted to provide helicopter services in Peru. 466 U.S. at 410. Four United States citizens were killed in a helicopter crash in Peru. Id. Their representatives filed suit against Helicol in Texas. Id. at 412. Helicol filed a motion to dismiss for lack of personal jurisdiction. Id. The motion was denied and ultimately the Supreme Court granted certiorari to determine whether a Texas court could lawfully exercise general jurisdiction over Helicol. Id. The Court found Helicol's contacts with Texas insufficient to support the exercise of general jurisdiction, even though Helicol had ventured to Texas and negotiated a contract for transportation in Texas, purchased approximately eighty percent of its helicopter fleet (worth over $ 4 million) and other related equipment from Texas vendors at regular intervals, and had sent pilots and other personnel to Texas for training. Id. at 411. The Court concluded that these contacts did not constitute the kind of "continuous and systematic general business contacts the Court found to exist in Perkins." Id. at 416. In Helicopteros Nacionales de Colombia, S.A. v. Hall, the Texas Supreme Court had ruled that a Columbian corporation had sufficient contacts with Texas to allow the exercise of jurisdiction. The corporation's contacts with Texas included sending its chief executive officer to Houston to negotiate a contract; accepting into its New York bank account checks drawn on a Houston bank; purchasing helicopters, equipment, and training services from a Texas corporation; and sending personnel for corporate training in Texas. The corporation had no place of business in Texas and had never been licensed to do business in Texas. The Supreme Court found that these contacts were not sufficient to establish general jurisdiction. 466 U.S. at 418-19.