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jurisdictionappealcorporation
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Vermeulen v. Renault, U.S.A., Inc., 985 F.2d 1534

Facts

On February 16, 1988, Laura Ann Vermeulen was involved in an accident while driving her 1982 Renault LeCar, resulting in a spinal injury that left her a quadriplegic. She had purchased the car shortly before the accident from her brother, and both were residents of North Carolina at the time of purchase. The manufacturer, RNUR, is a corporation wholly owned by the French government, which had entered into distribution agreements with American Motors Corporation (AMC) to market Renault vehicles in the United States.

On February 16, 1988, Laura Ann Vermeulen suffered an accident while driving her 1982 Renault LeCar near Lawrenceville, Georgia. She sustained a spinal injury that left her a quadriplegic.

Issue

Did the United States District Court for the Northern District of Georgia have personal jurisdiction over RNUR, the French manufacturer of the vehicle involved in the accident?

Did the United States District Court for the Northern District of Georgia have personal jurisdiction over RNUR, the French manufacturer of the vehicle involved in the accident?

Rule

Federal jurisdiction in cases against foreign states is governed by the Foreign Sovereign Immunities Act (FSIA), which allows for jurisdiction if the foreign state is not entitled to immunity under specific exceptions outlined in the Act.

The only possible source of federal jurisdiction in suits against corporations owned by foreign states is 28 U.S.C. § 1330(a), the subject matter jurisdiction provision relating to the Foreign Sovereign Immunities Act of 1976 (FSIA).

Analysis

The court determined that RNUR's design and manufacture of the LeCar were commercial activities connected to RNUR's operations outside the United States, which had a direct effect in the U.S. The court found that the injuries Vermeulen suffered were a direct consequence of RNUR's activities, thus satisfying the requirements for federal jurisdiction under the FSIA.

Applying these principles to the instant case, RNUR's design and manufacture of the Renault LeCar unquestionably were acts connected to a commercial activity of RNUR outside the United States.

Conclusion

The Court of Appeals reversed the district court's dismissal, ruling that federal jurisdiction existed under the FSIA and that the case could proceed in the federal district court in Georgia.

Thus, the court reversed the district court's dismissal, ruling that federal jurisdiction existed under the FSIA and that the case could proceed in the federal district court in Georgia.

Who won?

Laura Ann Vermeulen prevailed in the appeal because the court found that the federal district court had jurisdiction over RNUR under the Foreign Sovereign Immunities Act.

Vermeulen prevailed in the appeal because the court found that the federal district court had jurisdiction over RNUR under the Foreign Sovereign Immunities Act.

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