Even when the cause of action does not arise out of or relate to the foreign corporation's activities in the forum state, due process is not offended by a state's subjecting the corporation to its in personam jurisdiction when there are sufficient contacts between the state and the foreign corporation.
A foreign corporation entered into contract negotiations in Texas with decedents' employer to provide helicopter services. They signed a contract in Peru that provided for decedents' employer to make payments to the corporation's United States bank account. The corporation did not maintain a place of business in Texas, but purchased helicopter parts there and sent employees there for training. The decedents' representatives filed a wrongful death action against the corporation following the decedents' deaths in a helicopter crash in Peru. The Supreme Court of Texas ruled that the corporation's contacts with the state were sufficient to allow a state court to assert jurisdiction over the corporation in respondent representatives' cause of action against the corporation for the wrongful deaths of their decedents, which did not arise out of, and was unrelated to, the corporation's activities within the state. The foreign corporation appealed the decision to the Supreme Court of the United States.
Could a state acquire personal jurisdiction over a foreign corporation where the corporation contracted to provide services in another country, with some goods purchases and some training in the state?
The Supreme Court held that the corporation's contacts with the state were not sufficient to subject it to the state court's in personam jurisdiction. Because the representatives' causes of action for wrongful death arose out of the crash in Peru, and were not related to the corporation's contacts with the state, and the corporation's business contacts with the state were not continuous and systematic enough to satisfy the requirements of the Due Process Clause of the Fourteenth Amendment, the Supreme Court concluded that the state court lacked personal jurisdiction over the corporation.