Helicopteros Nacionales de Colombia v Hall

1983

Venue: SCOTUS

Facts: A Helicol chopper crashes in Peru, and 4 US folks die. The dead dudes were employed by Consorcio, a Peruvian joint venture formed by Texans to construct a Peruvian oil pipeline. Consorcio contracts with Helicol for transport; the contract is in Spanish on Peruvian government stationary and has a Peruvian choice-of-law clause. It specifies that Consorcio will pay Helico by depositing into a BofA account in NY.

Helicol buys helicopters from TX. It sent pilots there for training. And management and maintenance people also.


Posture: Suit in TX state court, apparently.

Issue: Do Helicol's contacts with TX suffice for the exercise of personal jurisdiction?

Holding: No. Reversed.

Rule: Mere purchases, even regular ones, are not enough if the cause of action isn't related to the purchase transactions.

Reasoning: These claims don't "arise out of" Helicol's TX activities.

Dicta: Brennan, dissenting: actually this was sufficient.