Martinez v. Aero Caribbean

General personal jurisdiction may be exercised over a corporation only when its contacts “render it essentially at home” in the state.

Following the crash of an airplane designed and built by Avions de Transport Régional (“ATR”), the heirs (“plaintiffs”) of one of the deceased passengers sued ATR in federal court in California. The district court dismissed the claim for lack of personal jurisdiction. On appeal, the Ninth Circuit affirmed the district court’s decision because ATR’s contacts in California did not render it subject to personal jurisdiction in that state. A court may exercise either specific or general jurisdiction over an out-of-state defendant. Under Daimler AG v. Bauman, “general personal jurisdiction may be exercised over a corporation only when its contacts ‘render it essentially at home’ in the state.” Plaintiffs tried to argue that ATR’s contacts with California created general jurisdiction based on its “engage[ment] in a substantial, continuous, and systematic course of business” in California; however, the panel ruled that those contacts were insufficient because general jurisdiction looks at a corporation’s place of incorporation and principal place of business. ATR’s principal place of business and headquarters are in France and it is not licensed to do business in California. Further, plaintiffs are unable to rely on Burnham v. Superior Court for use of tag jurisdiction when they served the vice president of ATR in California, because tag jurisdiction only applies to natural, not artificial, persons. ATR’s contacts in California did not “render it essentially at home” in that state, so plaintiffs’ claims against ATR lack personal jurisdiction in the federal court of California. AFFIRMED.