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Rao v. Era Alaska Airlines - 22 F. Supp. 3d 529 (D. Md. 2014)


To exercise general jurisdiction over a defendant, the defendant's activities in the state must be "continuous and systematic. If the cause of action arises out of the defendant's minimum contacts with the forum, the court may exercise specific jurisdiction. In determining whether the exercise of specific jurisdiction comports with due process, a court considers: (1) the extent to which the defendant has purposefully availed itself of the privilege of conducting activities in the state; (2) whether the plaintiff['s] claims arise out of those activities directed at the state; and (3) whether the exercise of personal jurisdiction would be constitutionally reasonable.


Maryland Plaintiffs sued an Alaska-based airline and other Alaska Defendants for torts arising out of the loss of personal property on or shortly after a flight operated by Defendant airline. Defendants have moved to dismiss for lack of personal jurisdiction on the grounds that Plaintiffs' claims arise out of a flight within Alaska operated by an airline that transacts business only within Alaska. Plaintiffs responded by arguing that jurisdiction in Maryland is proper because Plaintiffs purchased the tickets for their intra-Alaska flight over the internet, which is sufficient to give Maryland personal jurisdiction over Defendants.


Can the Maryland court exercise personal jurisdiction over the defendants?




The appellate court held that there is no question that the only services provided by Era were in Alaska, not in Maryland, and irrespective of where Plaintiffs actually purchased their tickets, long-arm jurisdiction simply does not arise. However, the motion to dismiss filed by the defendant was dismissed. The court held that rather than dismissing this case and forever bar Plaintiffs' claims, however dubious, the case was  transferred to the  United States District Court of Alaska.

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