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Law School Case Brief

Petroleum Helicopters, Inc. v. AVCO Corp. - 513 So. 2d 1188 (La. 1987)

Rule:

The determination that a Louisiana court's exercise of personal jurisdiction over a nonresident defendant comports with the requirements of due process also satisfies the requirements of the amended Louisiana Long-arm Statute, which applies retroactively. 

Facts:

Defendant, a California manufacturer, objected to the Louisiana court's exercise of personal jurisdiction in a suit filed by plaintiff, a Louisiana helicopter company, which claimed damages resulting from defects in defendant's flotation devices. Although defendant had transacted business extensively in Louisiana, it had never supplied these particular flotation devices directly to anyone in Louisiana. The federal circuit court determined that there were sufficient minimum contacts to satisfy due process, but found that La. Rev. Stat. Ann. § 13:3201, given a literal interpretation, arguably did not provide jurisdiction over defendant at the time of the accident. 

Issue:

Does La. Rev. Stat. Ann. § 13:3201 et seq., the Louisiana Long-arm Statute, confer personal jurisdiction over a nonresident defendant when the cause of action did not arise out of any conduct by the nonresident that was specifically enumerated in the statute?

Answer:

Yes

Conclusion:

The court concluded that the certified question was rendered moot by the enactment of an amendment, La. Rev. Stat. Ann. § 13:3201(B), which expressly authorized the exercise of jurisdiction to the full limits of constitutional due process. The court also held that § 13:3201(B) applied retroactively because it was procedural. The court concluded that the limits of the Louisiana Long-arm Statute and the limits of constitutional due process were coextensive.

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