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Illinois appellate court affirms state’s jurisdiction over Texas aircraft company
June 6, 2019An out-of-state aircraft company can be sued for negligence in Illinois for injuries that occurred in the state because the defendant marketed its products nationwide and had several repeat customers in Illinois, a state appellate court has ruled. It also determined that it was reasonable to exercise jurisdiction over the defendant (Schaefer v. Synergy Flight Ctr., 2019 WL 2128272 (Ill. Ct. App. May 13, 2019).)
After seven men were killed in a plane crash in Illinois in 2015, their estates filed a negligence suit against RAM Aircraft, a Texas-based company that overhauls planes and sells aircraft parts. The plaintiffs claimed that the defendant negligently overhauled and repaired parts of the plane that crashed. The defendant had worked on the parts in Texas, shipped them to another company in Indiana, and then sent them to Synergy Flight Center in Illinois, which ultimately installed the parts on the plane. The defendant moved for summary judgment for lack of personal jurisdiction, which the trial court denied, and the appellate court affirmed that ruling.
Relying on a previous case, Russell v. SNFA (987 N.E.2d 778 (Ill. 2013)), the court explained that it could assert specific jurisdiction over the defendant. In Russell, a French company was sued after a helicopter crashed and killed an employee of an air ambulance service in Illinois. The employee’s estate claimed that defective tail rotor bearings manufactured by SNFA caused the crash. SNFA had no offices, assets, or employees in the state, nor was it licensed to conduct business there. It also had no direct customers in the United States; all of its U.S.-based business was through three aircraft companies, one with a location in Illinois. While the Illinois Supreme Court determined that it could not exercise general jurisdiction over SNFA, it found it could exercise specific jurisdiction because SNFA’s business with the Illinois company showed that it “‘benefitted from Illinois’ system of laws, infrastructure, and business climate’” and that it had sufficient contacts with the forum state because it distributed its products there, it had an ongoing business relationship with an Illinois customer, and there was adequate evidence that the defendant’s negligence had caused an injury in the state.
Comparing the analysis in Russell to the immediate case, the court reasoned that the facts were even stronger to support specific jurisdiction. For example, RAM Aircraft had multiple customers in Illinois (which accounted for up to 2% of its annual revenue), it advertised in nationally distributed aviation magazines, and it marketed its products to general aviation fleets throughout the country.
The court next considered whether exercising specific jurisdiction over the defendant was reasonable, evaluating the burden on the defendant and the relative interests of the forum state, the plaintiff, and other potential forums. It concluded that “Illinois has an indisputable interest” in the case, as does the plaintiff, and that no other forum than Texas had a similar interest.
The only remaining question was whether the burden of defending the case in Illinois would be undue—to which the court said no, noting, “The burden on a Texas company defending itself in Illinois is not as heavy as the burden on a French company defending itself in Illinois.” It also referred to another Illinois Supreme Court ruling (Gray v. Am. Radiator & Standard Sanitary Corp., 176 N.E.2d 761 (Ill. 1961)) to explain that “where the alleged liability arises . . . from the manufacture of products presumably sold in contemplation of use here, it should not matter that the purchase was made from an independent middleman or that someone other than the defendant shipped the product into this State.”