LNS Enterprises, LLC v. Continental Motors, Inc., No. 20-16897 (9th Cir. 2022)
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Plaintiffs purchased a 2006 aircraft from an unidentified individual in 2016. In 2017, the plane was forced to make an emergency crash landing. The aircraft suffered significant structural damage and the complete loss of its engine, but no one was killed in the crash. Various actors were involved in the manufacture and maintenance of the aircraft, including Continental, which manufactured and shipped the engine to Columbia in Oregon, where it was installed. Cessna acquired assets from Columbia but did not assume Continental’s liabilities apart from express, written aircraft warranties still in effect at the time of acquisition. In 2014, Cessna became a subsidiary of Textron.
Plaintiffs filed suit in Arizona, where the crash occurred. The case was removed to federal court. Four of the 15 original defendants—including Continental and Textron—were dismissed for lack of personal jurisdiction, finding that Plaintiffs had failed to show “that any of the moving Defendants are meaningfully connected to Arizona in such a way that renders them subject to this Court’s exercise of personal jurisdiction.” The Ninth Circuit affirmed, noting that the Plaintiffs have conceded that Arizona does not have general jurisdiction over either Defendant. Plaintiffs also failed to establish a prima facie case of specific jurisdiction over either Defendant, failing to establish that Defendants had sufficient minimum contacts with Arizona that are related to Plaintiffs’ claims. Plaintiffs’ reasons for seeking jurisdictional discovery with regard to Defendants’ contacts with Arizona were properly deemed insufficient.
Court Description: Personal Jurisdiction. The panel affirmed the district court’s decision to dismiss a civil action arising from a nonfatal airplane crash for lack of personal jurisdiction and to deny plaintiffs’ request for jurisdictional discovery. Plaintiffs conceded that the Arizona district court lacked general jurisdiction over two defendants, Continental Motors, Inc., and Textron Aviation, Inc. Citing Ford Motor * The Honorable Ronald Lee Gilman, United States Circuit Judge for the U.S. Court of Appeals for the Sixth Circuit, sitting by designation. LNS ENTERS V. CONTINENTAL MOTORS 3 Co. v. Montana Eighth Judicial Dist. Court, 141 S. Ct. 1017 (2021), the panel held that plaintiffs also failed to establish a prima facie case of specific jurisdiction over either defendant because they did not demonstrate that defendants had sufficient minimum contacts with Arizona that were related to plaintiffs’ claims. The panel also held that the district court properly denied plaintiffs’ request for jurisdictional discovery with regard to defendants’ contacts with Arizona because the request amounted to nothing more than a hunch that discovery might reveal facts relevant to the jurisdictional analysis.
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