ERICA DAVIS, ET AL V. CRANFIELD AEROSPACE SOLUTIONS, No. 22-35099 (9th Cir. 2023)
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In November 2018, a Cessna Model 525 corporate jet tried to fly from Sellersburg, Indiana, to Chicago, Illinois. It never made it to Chicago. It crashed a few minutes after takeoff in Clark County, Indiana. The pilot of the plane and the two passengers were killed instantly. Representatives for the three decedents brought this wrongful death and product liability suit against Cranfield Aerospace Solutions, LLC, in the District of Idaho. Cranfield is incorporated in and has its principal place of business in England. Appellants alleged that a load alleviation system, the Tamarack Active Winglet Load System—trademarked as the ATLAS system—caused the plane crash. Cranfield helped Tamarack obtain the Federal Aviation Administration supplemental type certification for the ATLAS system.
The Ninth Circuit affirmed the Idaho federal district court’s judgment dismissing for lack of personal jurisdiction over. The panel held when considering specific jurisdiction under the first prong, courts should comprehensively evaluate the extent of the defendant’s contacts with the forum state and those contacts’ relationship to the plaintiffs’ claims—which may mean looking at both purposeful availment and purposeful direction. The panel held that under either approach, jurisdiction over Cranfield in Idaho was lacking. The purposeful direction test cannot support jurisdiction here because Appellants failed to allege that Cranfield injured them in Idaho. The panel agreed with the district court that Appellants failed to establish that Cranfield purposefully availed itself of the benefits and protections of Idaho. The panel declined to proceed to the remaining two prongs of the specific jurisdiction test and held that the district court properly declined to exercise jurisdiction over Cranfield.
Court Description: Personal Jurisdiction The panel affirmed the Idaho federal district court’s judgment dismissing, for lack of personal jurisdiction over an English corporation, a diversity action brought by plaintiffs from Louisiana and Indiana for an accident that occurred in Indiana.
Representatives for the three decedents of a plane crash that occurred in Indiana brought a wrongful death and product liability suit against Cranfield Aerospace Solutions, Limited, in the District of Idaho. The representatives for two decedents are residents of Indiana, while the third decedent’s representatives reside in Louisiana. Cranfield is * The Honorable M. Miller Baker, Judge for the United States Court of International Trade, sitting by designation.
incorporated in and has its principal place of business in England. Appellants alleged that a load alleviation system, the Tamarack Active Winglet Load System—trademarked as the ATLAS system—caused the plane crash. Cranfield helped Tamarack obtain the Federal Aviation Administration supplemental type certification for the ATLAS system.
Idaho’s long-arm statute authorizes the exercise of all the jurisdiction available to the State of Idaho under the due process clause of the United States Constitution.
Only specific jurisdiction is at issue in this case. This court uses a three-part test to determine whether specific jurisdiction exists: (1) the non-resident defendant must purposefully direct his activities or consummate some transaction with the forum or resident thereof; or perform some act by which he purposefully avails himself of the privilege of conducting activities in the forum, thereby invoking the benefits and protections of its laws; (2) the claim must be one which arises out of or relates to the defendant’s forum-related activities; and (3) the exercise of jurisdiction must comport with fair play and substantial justice, i.e. it must be reasonable.
The panel held when considering specific jurisdiction under the first prong, courts should comprehensively evaluate the extent of the defendant’s contacts with the forum state and those contacts’ relationship to the plaintiffs’ claims—which may mean looking at both purposeful availment and purposeful direction. The panel held that under either approach, jurisdiction over Cranfield in Idaho was lacking. The purposeful direction test cannot support jurisdiction here because Appellants failed to allege that Cranfield injured them in Idaho. The panel agreed with the district court that Appellants failed to establish that Cranfield purposefully availed itself of the benefits and protections of Idaho. While Tamarack was an Idaho resident, there was no evidence that Cranfield sought out Tamarack in Idaho or benefitted from Tamarack’s residence in Idaho. Neither the contract’s negotiations, terms, nor contemplated consequences established that Cranfield formed a substantial connection with Idaho. The panel concluded that the two trips by Cranfield employees to Idaho were too attenuated to establish minimum contacts with the State. None of Cranfield’s actual course of dealings in Idaho was so substantial or widespread that it reflected Cranfield’s attempt to gain the “benefits and protections” of the forum state.
Because Appellants’ allegations failed to establish that Cranfield had sufficient minimum contacts with Idaho, the panel declined to proceed to the remaining two prongs of the specific jurisdiction test, and held that the district court properly declined to exercise jurisdiction over Cranfield.
Judge Baker dissented in part. He joined Parts I, II.A., II.B. except for its final sentence, and II.C. of the panel’s opinion. He parted company, however, with the majority’s conclusion that Plaintiffs did not demonstrate that the U.K.-based Cranfield Aerospace Solutions, Ltd., purposefully availed itself of the forum state, Idaho. In his view, Plaintiffs lopsidedly carried that burden by showing that Cranfield undertook continuing obligations entailing substantial activity directed toward Tamarack Aerospace Group, Inc., in Idaho for over six years.
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