District Court Finds No General Personal Jurisdiction Over Mexican Helicopter Operator Arising Out of Accident in Mexico

The World in U.S. Courts: Summer 2014 - Personal Jurisdiction | June.27.2014

Gonzales v. Seadrill Americas, Ltd., United States District Court for the Southern District of Texas, June 27, 2014

Plaintiffs are two offshore-oil-rig workers who were injured during a helicopter ride in Mexico. Plaintiffs filed suit against the oil rig operator and the helicopter operator, Pegaso Mexico, a Mexican corporation. Defendant oil rig operator also filed a cross-claim against Pegaso. Pegaso moved to dismiss the claims for lack of personal jurisdiction.

After jurisdictional discovery, the Court first held that general personal jurisdiction could not be found. Because Pegaso operated almost exclusively in Mexico, operating only three to five flights a year into Texas, and had no offices or employees in the United States, Pegaso could not be said to be “at home” in the United States. Although Pegaso’s subsidiaries operated in the United States, leasing three helicopters from American companies that are subleased to Pegaso, the law does not permit the actions of a U.S. subsidiary to be imputed to the parent. However, even if the subsidiaries contacts were imputed, the Court nevertheless found the contacts were not sufficient to confer jurisdiction. As to specific personal jurisdiction, the Court held that although the contacts may be sufficient under the less exacting specific jurisdiction standard, the Plaintiffs’ injuries did not arise from those contacts. As such, specific personal jurisdiction could not be found.

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