Illinois Supreme Court Finds “Specific” Personal Jurisdiction Over French Manufacturer That Only Sold Related Products In The State

The World in U.S. Courts: Summer 2013 - Personal Jurisdiction | May.28.2013

Russell v. SNFA (Supreme Court of Illinois, May 28, 2013)

In a product liability suit stemming from a fatal helicopter crash, the plaintiff claimed defendant SNFA, a manufacturer of custom-made aerospace bearings, could be sued in Illinois based on a high volume of indirect and direct sales in the United States and Illinois. The Court found “specific” personal jurisdiction had been established because SNFA purposefully directed its business activities at the United States and Illinois, both directly and through an American distributor.

SNFA manufactured both airplane and helicopter bearings, and claimed that its helicopter bearings, at issue in the suit, were only indirectly sold in the United States through a distributor. However, SNFA sold over $1 million worth of airplane bearings directly to a company in Illinois. The Court rejected SNFA’s attempt to distinguish between “subcategories” of its products and held that “specific” personal jurisdiction could be established even though the suit involved only helicopter bearings, not the airplane bearings directly sold in Illinois. The Court further held that the direct sales to an Illinois company, in combination with several in-person sales visits, were sufficient to establish minimum contacts with Illinois to support jurisdiction.

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