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Keywords

contractplaintiffjurisdictionappealtrialcorporationdue process
contractplaintiffjurisdictionappealtrialcorporation

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Hall v. Helicopteros Nacionales De Colombia, S.A. (Helicol), 638 S.W.2d 870

Facts

Elizabeth Hall and other plaintiffs, survivors of four U.S. citizens killed in a helicopter crash in Peru, sued Helicol, the helicopter's owner and operator, in Harris County, Texas. Helicol contested the jurisdiction of the Texas court, claiming it did not conduct business in Texas. However, evidence showed that Helicol had significant business dealings in Texas, including purchasing helicopters, negotiating contracts, and sending personnel for training. The deceased workers were hired in Texas and sent to Peru for a pipeline project, which further connected the case to Texas.

Elizabeth Hall and other plaintiffs, survivors of four U.S. citizens killed in a helicopter crash in Peru, sued Helicol, the helicopter's owner and operator, in Harris County, Texas.

Issue

Was Helicol amenable to jurisdiction in Texas based on its contacts with the state?

Was Helicol amenable to jurisdiction in Texas based on its contacts with the state?

Rule

A nonresident corporation is deemed to be 'doing business' in Texas if it has sufficient minimum contacts with the state such that the exercise of jurisdiction does not offend traditional notions of fair play and substantial justice.

A nonresident corporation is deemed to be 'doing business' in Texas if it has sufficient minimum contacts with the state such that the exercise of jurisdiction does not offend traditional notions of fair play and substantial justice.

Analysis

The court found that Helicol's extensive business activities in Texas, including purchasing helicopters, negotiating contracts, and sending employees for training, constituted sufficient minimum contacts. The court applied the three-prong test from O'Brien v. Lanpar Company, concluding that Helicol purposefully engaged in activities in Texas, the cause of action arose from those activities, and exercising jurisdiction would not violate due process.

The court found that Helicol's extensive business activities in Texas, including purchasing helicopters, negotiating contracts, and sending employees for training, constituted sufficient minimum contacts.

Conclusion

The Supreme Court of Texas reversed the Court of Civil Appeals' judgment and affirmed the trial court's ruling, allowing the case to proceed in Texas.

The Supreme Court of Texas reversed the Court of Civil Appeals' judgment and affirmed the trial court's ruling, allowing the case to proceed in Texas.

Who won?

Elizabeth Hall and the other plaintiffs prevailed because the court determined that Helicol had sufficient contacts with Texas to establish jurisdiction.

Elizabeth Hall and the other plaintiffs prevailed because the court determined that Helicol had sufficient contacts with Texas to establish jurisdiction.

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