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Two important aspects necessary to assert personal jurisdiction over a nonresident defendant are (1) the relationship between the defendant and the forum state must arise out of contacts that the defendant created with the forum state and (2) "minimum contacts" analysis looks to the defendant's contacts with the forum state itself, not the defendant's contact with persons who reside there. While physical presence in the forum is not a prerequisite to jurisdiction, the plaintiff cannot be the only link between the defendant and the forum.
Plaintiff, EagleMed, L.L.C., purchased an unassembled helicopter from Airbus Helicopters, Inc. in Texas. Plaintiff transported the helicopter to Wichita, Kansas, where it was assembled at plaintiff’s headquarters to be used in Oklahoma as an ambulance helicopter. The engine used in the helicopter was manufactured by defendant, Honeywell International, Inc. with design installation instructions by the defendant Soloy, L.L.C. The helicopter crashed in Oklahoma and killed two Oklahoma residents: the pilot and a flight nurse. The pilot's widow/personal representative, EagleMed, and the helicopter's insurer, Starr Indemnity and Liability Company (Star), filed a products liability/negligence lawsuit in Oklahoma County, Oklahoma, against Airbus, Soloy, and Honeywell. The trial court dismissed Airbus and Soloy for lack of personal jurisdiction, and the Court of Civil Appeals affirmed. A writ of certiorari was granted.
Did the defendants, whose products were used to make an ambulance helicopter, have sufficient minimum contacts with the State of Oklahoma in order to establish personal jurisdiction over them after the helicopter crashed in Oklahoma?
The Court held that the Oklahoma court did not have personal jurisdiction over the defendant manufacturer or the defendant provider of the engine conversion kit whose products were used to make the ambulance helicopter that crashed in Oklahoma, killing two Oklahoma residents, because they did not have sufficient minimum contacts with Oklahoma. A "sliding scale" approach, or "totality of the contacts," or "stream of commerce" approach was insufficient to establish specific personal jurisdiction. According to the Court, although the crash happened in Oklahoma, the helicopter took off from a base in Oklahoma, the two people killed were citizens of Oklahoma, and most of the harm from the incident occurred in Oklahoma, such facts, alone, were insufficient for specific personal jurisdiction without the defendants having further direct and specific conduct with Oklahoma directly related to the incident.