West v Bell Helicopter et al

2011 DNH 013
CourtDistrict Court, D. New Hampshire
DecidedJanuary 28, 2011
DocketCV-10-214-JL
StatusPublished

This text of 2011 DNH 013 (West v Bell Helicopter et al) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
West v Bell Helicopter et al, 2011 DNH 013 (D.N.H. 2011).

Opinion

West v Bell Helicopter et al CV-10-214-JL 1/28/11 UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE

Kurt West

v. Civil N o . 10-cv-214-JL Opinion N o . 2011 DNH 013 Bell Helicopter Textron, Inc. et al.

MEMORANDUM ORDER

This products liability action arises out of a helicopter

crash in Bow, New Hampshire. The pilot, plaintiff Kurt West,

alleges that the helicopter experienced an “uncommanded shutdown”

in which the flow of fuel to the engine was suddenly cut off

without warning, forcing him to land through a maneuver known as

“autorotation.” This landing was violent and caused serious

injuries to West. He alleges that the shutdown occurred due to a

malfunction with the aircraft’s “Full Authority Digital Engine

Control,” or “FADEC,” part of its electronic control unit, or

“ECU.” During the alleged shutdown, “the computer seized control

of the engine” and caused a malfunction in the fuel shutoff valve

and the hydromechanical unit, or “HMU,” which “interfaces with

the FADEC to control the flow of fuel to the engine.”

West, a citizen of Massachusetts, has brought suit against a

number of defendants, including: the manufacturer of the

helicopter, Bell Helicopter Textron, Inc.; the manufacturer of

the ECU, Goodrich Pump & Engine Control Systems, Inc. (which is also allegedly the successor-in-interest to the entity that

manufactured the FADEC and the H M U ) ; the manufacturer of the

engine, Rolls Royce Corporation; and the alleged manufacturer of

the fuel shutoff valve, Circor Aerospace, Inc. Each of these

corporations has its principal place of business outside of

Massachusetts, so this court has diversity jurisdiction under 28

U.S.C. § 1332(a)(1). Circor, whose principal place of business

is in Corona, California, has moved to dismiss for lack of

personal jurisdiction.1 See Fed. R. Civ. P.12(b)(2).

“Personal jurisdiction implicates the power of a court over

a defendant . . . . [B]oth its source and its outer limits are

defined exclusively by the Constitution,” namely, the due process

clause of the Fourteenth Amendment. Foster-Miller, Inc. v .

Babcock & Wilcox Can., 46 F.3d 1 3 8 , 143-44 (1st Cir. 1995)

(citing Ins. Corp. of Ir., Ltd. v . Compagnie des Bauxites de

Guinee, 456 U.S. 6 9 4 , 702 (1982)); U.S. Const. Am. XIV. Due

process encompasses both general jurisdiction, based on the

defendant’s continuous and systematic activity in the forum

state, and specific jurisdiction, based on the nexus between the

plaintiff’s claims and the defendant’s forum-based activities.

1 While this court ordinarily hears oral argument on dispositive motions, both West and Circor indicated at the preliminary pretrial conference that they preferred to have the motion decided without oral argument.

2 See, e.g., Hannon v . Beard, 524 F.3d 275, 279 (1st Cir. 2008).

West admittedly “does not contend that [Circor] had continuous

and systematic contact with New Hampshire such that general

jurisdiction exists,” so he must show specific jurisdiction.

This showing normally consists of two parts: first, that

applicable long arm statute provides for jurisdiction over the

defendant and, second, if it does, that exercising jurisdiction

comports with due process. See, e.g., Hannon, 524 F.3d at 280.

As the parties recognize, though, New Hampshire’s applicable

long-arm statute, N.H. Rev. Stat. Ann. 510:4, allows jurisdiction

to the same extent allowed by the Constitution, so the court

moves directly to the constitutional analysis.2 See Phillips

2 West argues that, because the New Hampshire “long-arm statute calls for jurisdiction where the defendant has caused tortious injury within this state,” the state legislature “is apparently of the view that such intra-state injury i s , a fortiori, sufficient for the assertion of personal jurisdiction under the due process clause.” But the New Hampshire long-arm statute does not actually say that causing tortious injury within the state subjects a person to jurisdiction here. See N.H. Rev. Stat. Ann. § 510:4, I . Instead, the New Hampshire Supreme Court, construing the statute “in its broadest legal sense,” has held that “the fact that only the alleged injury occurred within the State does not preclude New Hampshire courts from subjecting a nonresident to their jurisdiction under the long-arm statute.” Tavoularis v . Womer, 123 N.H. 423, 426 (1983). The statute, then, reflects no legislative “view” that doing so would comport with due process (and, even if it did, of course, that “view” would not carry much if any weight in this court’s analysis).

3 Exeter Acad. v . Howard Phillips Fund, 196 F.3d 2 8 4 , 287 (1st Cir.

1999); Sawtelle v . Farrell, 70 F.3d 1381, 1388 (1st Cir. 1995).

For this court to exercise personal jurisdiction over Circor

in New Hampshire, the company must have “sufficient minimum

contacts with the state such that ‘maintenance of the suit does

not offend traditional notions of fair play and substantial

justice.’” Adelson v . Hananel, 510 F.3d 4 3 , 49 (1st Cir. 2007)

(quoting Int’l Shoe C o . v . Washington, 326 U.S. 3 1 0 , 316 (1945))

(further internal quotation marks omitted). This constitutional

standard consists of three elements: relatedness, purposeful

availment, and reasonableness. See, e.g., Phillips v . Prairie

Eye Ctr., 530 F.3d 2 2 , 27 (1st Cir. 2008). To carry its burden

to show personal jurisdiction, “[t]he plaintiff must demonstrate

that each of these three requirements is satisfied.” Id.

The court agrees with Circor that West’s jurisdictional

argument flunks the relatedness inquiry. “Generally, relatedness

refers to the requirement that the underlying claim ‘arise out

of’ or be ‘related to’ the activities within the forum state.”

Adelson, 510 F.3d at 4 9 . Under this test, personal jurisdiction

will not lie if “the connection between the cause of action and

the defendant’s in-state conduct seems attenuated and indirect.

Instead, the defendant’s in-state conduct must form an important,

or at least material, element of proof in the plaintiff’s case.”

4 United Elec., Radio & Mach. Workers of Am. v . 163 Pleasant S t .

Corp., 960 F.2d 1080, 1089 (1st Cir. 1992) (bracketing and

quotation marks omitted).

In his amended complaint, West asserts three separate causes

of action against Circor: breach of warranty (count 4 ) ,

negligent design and manufacture (count 8 ) , and strict liability

(count 1 2 ) . But West does not allege any facts that could

connect these claims to any conduct by Circor in New Hampshire,

i.e., that any of its activities in designing, manufacturing, or

making warranties about the allegedly defective fuel valve

occurred in New Hampshire. Indeed, West does not allege any

conduct by Circor in New Hampshire at all. In the absence of

those allegations, this court cannot exercise jurisdiction over

West’s claims for breach of warranty, negligent design and

manufacture, or strict liability against Circor. See, e.g.,

D’Jamoos v .

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Rodgers v. American Honda Motor Co.
46 F.3d 1 (First Circuit, 1995)
Hannon v. Beard
524 F.3d 275 (First Circuit, 2008)
DeCaire v. Mukasey
530 F.3d 1 (First Circuit, 2008)
Arthur F. Sawtelle, Etc. v. George E. Farrell
70 F.3d 1381 (First Circuit, 1995)
Associated Press v. United States
326 U.S. 1 (Supreme Court, 1945)
Tavoularis v. Womer
462 A.2d 110 (Supreme Court of New Hampshire, 1983)
Convertino v. United States Department of Justice
669 F. Supp. 2d 1 (District of Columbia, 2009)
D’Jamoos v. Atlas Aircraft, et al.
2008 DNH 203 (D. New Hampshire, 2008)
25 CP LLC v. Firstenberg Mach.
2009 DNH 185 (D. New Hampshire, 2009)
Brook Village v. HUD
2008 DNH 001 (D. New Hampshire, 2008)

Cite This Page — Counsel Stack

Bluebook (online)
2011 DNH 013, Counsel Stack Legal Research, https://law.counselstack.com/opinion/west-v-bell-helicopter-et-al-nhd-2011.