Noboa v. Barcelo Corp. Empresaria, SA, No. 15-2001 (7th Cir. 2016)

Noboa, while living in Illinois, booked a trip to Mexico by using the Orbitz website. In the lobby of the Barcelo hotel, she booked an eco-tour, operated by Rancho. During the tour, the all-terrain vehicle in which Noboa was riding overturned. She died as a result of her injuries. The district court dismissed her estate's suit against Barcelo and Rancho, finding neither company subject to jurisdiction in Illinois. The Seventh Circuit affirmed, rejecting an argument that Noboa's death was connected to Illinois through a causal chain that began with her booking the trip while in Illinois.