Patterson v. Aker Solutions Inc., No. 15-30690 (5th Cir. 2016)Annotate this Case
Plaintiff, a U.S. citizen working for Blue Offshore, allegedly sustained a knee injury while working on board a Luxembourg-flagged vessel that was located off the coast of Russia. Plaintiff filed suit against Blue Offshore and two other companies, Aker Solutions and FMC Technologies, alleging negligence. Plaintiff later amended his complaint and added more defendants, including FMC Kongsberg and FMC Eurasia. After completion of the jurisdictional discovery, the district court found that neither specific nor general personal jurisdiction existed over Aker Subsea or FMC Kongsberg. Therefore, the district court dismissed these parties from the suit. At issue in this appeal is whether the district court erred in dismissing Aker Subsea under Rule 12(b)(2). The court concluded that exercising general personal jurisdiction over Aker Subsea would be inappropriate where Aker Subsea’s limited contacts with the United States - eleven secondment agreements - are insufficient to satisfy due process concerns. Accordingly, the court affirmed the judgment.