LNS Enterprises, LLC v. Continental Motors, Inc., No. 20-16897 (9th Cir. 2022)
Annotate this Case
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.