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

466 U.S. 408 (1983)


Petitioner Helicol was a Colombian corporation with its principal place of business in Bogota.  After a helicopter owned by Helicol crashed in Peru and respondents, survivors and representatives of four U.S. citizens who died in the crash, sued Helicol.  The decedents were employed by Consorcio, a Peruvian joint venture formed by Texans to enable them to enter into a deal to construct an oil pipeline in Peru.  Consorcio negotiated the terms of the transportation-services contract with Helicol in Texas and it was formally signed later in Peru in 1974.  The contract was written in Spanish on official government stationery and provided that the residence of all parties would be Lima, Peru, that Peruvian courts had jurisdiction over all controversies arising out of the contract, and that Consorcio would make payment to Helicol’s Bank of America account in New York City.  From 1970-74, Helicol had purchased about 80% of its helicopter fleet and other equipment from a company in Fort Worth, and sent pilots and other personnel to Forth Worth for training and consultation.  Helicol received over $5 million in payments from Consorcio draw upon First City National Bank of Houston.

Procedural History

The Texas Supreme Court held that Helicol had sufficient contacts with the state of Texas to allow a Texas state court to exercise jurisdiction.


Whether the contacts of a foreign corporation with the state of Texas were sufficient to allow a Texas state court to assert jurisdiction over the corporation in a cause of action not arising out of or related to the corporation’s activities within the state.

Holding / Rule

(Blackmun) No.  Reversed.  For a forum state to assert in personam jurisdiction over a foreign corporation for a cause of action that does not arise out of or relate to the corporation’s activities in the state, the corporation must have continuous and systematic general business contacts with the forum state.


Due process may permit a forum state to exercise jurisdiction over a foreign corporation for a cause of action that does not arise out of or relate to the corporation’s activities in the state if there are sufficient contacts between the state and corporation.  But here, the contacts were too sporadic and not of a continuous and systematic nature.  Helicol’s CEO made a single trip to Texas to negotiate the contract with Consorcio.  Helicol’s acceptance of checks drawn from Consorcio’s Texas bank account was of negligible significance—there was no indication that Helicol requested or negotiated this.  Nor did Helicol’s mere purchase of a package of goods and services from a Texas corporation (including the training sessions in Texas), which the cause of action did not relate to, constitute sufficient contacts.

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