Lawsuit against Robinson Helicopters dropped
January 28, 2016 By Holland & Knight
A federal court in the District of Arizona, applying Ninth Circuit precedent, has weighed in on the limitations of personal jurisdiction over a non-resident engine manufacturer in the context of tort claims alleging failure to warn about changes in a helicopter engine Operation and Maintenance Manual (“OMM”). The court reached the correct result in view of the 2014 U.S. Supreme Court decisions in Daimler1 and Walden2 that refined the contours of general and specific jurisdiction, respectively.
In the District of Arizona case, Quantum Leasing, LLC v. Robinson Helicopter, Inc., the complaint alleged that in 2011 plaintiff Quantum Leasing ordered a helicopter from non-party Quantum Helicopter in Arizona, an independent seller of aircraft. The helicopter was manufactured by Robinson Helicopter Company (“Robinson”), located in California. The helicopter utilized a Rolls-Royce RR300 engine manufactured by Rolls-Royce Corporation (RRC) in Indiana and sold to Robinson in Indiana. Quantum Helicopter delivered the helicopter to Quantum Leasing by taking delivery of the helicopter from Robinson’s factory in California and flying it to Arizona to deliver it to Quantum Leasing.
The helicopter experienced a “hot start” in May 2013. In September 2014, RRC issued a change to its OMM regarding hot starts. Quantum Leasing alleged that RRC did not send any notification to Quantum Leasing of the amended OMM, although RRC did send an email to Quantum Helicopter. In October 2014, the helicopter experienced another hot start resulting in its grounding. After commencing litigation in June 2015, Quantum Leasing filed an amended complaint in September 2015 asserting claims against RRC for negligence, negligent misrepresentation, consumer fraud, and failure to warn. Underlying each of these claims was the theory that RRC failed to advise Quantum Leasing about the changes in the OMM regarding hot starts. RRC moved to dismiss on the basis that the Arizona court lacked personal jurisdiction over RRC. | READ MORE