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

Summary

The United States Supreme Court held that Texas courts could not exercise general personal jurisdiction over Helicol, a Colombian corporation, based on its Texas contacts. The contacts included contract negotiations, purchases of helicopters and equipment, employee training, and receipt of payments drawn on a Texas bank, but the Court concluded they were not sufficiently continuous and systematic. The Court reversed the judgment of the Supreme Court of Texas.

Holdings

1. Texas could not constitutionally exercise general personal jurisdiction over Helicol because its contacts with Texas were insufficiently continuous and systematic.
2. Mere purchases, even if occurring at regular intervals, and related training trips are not sufficient by themselves to support general personal jurisdiction over a nonresident corporation when the cause of action is unrelated to those purchases.
3. The Court declined to adopt or apply a doctrine of jurisdiction by necessity on the record presented.

Questions Presented

1. Whether Helicol's contacts with Texas were sufficiently continuous and systematic to permit Texas courts to exercise general personal jurisdiction over it for claims unrelated to those contacts.
2. Whether Helicol's purchases, related training trips, contract-negotiation meeting, and receipt of checks drawn on a Texas bank constituted constitutionally sufficient minimum contacts.
3. Whether the Court should adopt a doctrine of jurisdiction by necessity as an alternative basis for Texas jurisdiction.

Disposition

reversed