In law, jurisdiction refers to the right of a court to enter judgment on a particular case. Because different courts must follow different laws, decisions of jurisdiction are extremely important in a case’s potential outcome. Take for instance the product liability lawsuit of John Russell v. SNFA, No. 1-09-3012 (2011), in which the trial court dismissed the lawsuit because it felt the court did not have proper jurisdiction over the defendant. Fortunately for the plaintiff, the Illinois Appellate Court felt differently and reversed the lower court’s decision, thereby allowing the case to proceed.
The issue in Russell arose out of a 2003 helicopter crash in Illinois. At the time of the crash, the decedent, Michael Russell, was working as a helicopter pilot for Air Angels, a medical airlift service. Russell was the only person in the helicopter at the time and consequently the only victim of the helicopter crash.
Russell’s surviving family members filed an Illinois product defect lawsuit against SNFA Group, which manufactured a custom ball bearing that was installed in the helicopter at the time of the crash. The lawsuit alleged that the helicopter crash was caused when one of its tail-rotor drive shaft bearings failed, which in turn caused the drive shaft to fracture, causing the tail rotor to be inoperable. Since SNFA manufactured the drive shaft bearing whose failure allegedly caused the helicopter to spin out of control, the family contended that its negligence was responsible for Russell’s death.
The issue of jurisdiction comes into play because SNFA Group did not sell its bearings directly to Air Angels. The bearings were originally manufactured in France and were then sold to an Italian company, Agusta, who then sold the bearings to its American subsidiary, Agusta Aerospace Corporation (Agusta AC). Agusta AC then sold the bearings to Metro Aviation, a Louisiana company that serviced Air Angel’s helicopter.
So while the European-made part ended up in an American-owned helicopter, it was not sold directly by SNFA. In fact, SNFA does not have any American customers for its custom-made bearings; all of its customers are European. Because the plaintiffs were unable to show that SNFA had any significant business in Illinois, the trial court dismissed their claim for lack of personal jurisdiction.
In its review of Russell, the Illinois Appellate Court first examined the Illinois statute as to personal jurisdiction, 735 ILCS 5/2-209(a)(1) through (a)(14). The court pointed out that there were only two provisions under which Illinois courts have jurisdiction over corporations: when a corporation organized under Illinois laws, or when corporation does business within Illinois. And while neither of these applied to SNFA, the court pointed out that there was also a due process clause which allowed “personal jurisdiction over a nonresident defendant to those instances where the defendant had at least ‘minimum contacts’ with the state.”
In order to determine whether the court can apply general or specific jurisdiction, the court must determine what sort of contact the defendant had with Illinois. Under general jurisdiction, the defendant must have “continuous and systematic” business contacts; this type of jurisdiction does not apply to SNFA. However, the court found that SNFA did have specific jurisdiction, which applies “when the cause of action [arises] out of defendant’s contacts with the forum state.”
To help it determine that SNFA did have specific jurisdiction, the appellate court reviewed Rockwell International Corp. v. Costruzioni Aeronautiche Giovanni Agusta, S.p.A., 553 F. Supp. 328 (E.D. Pa. 1982. Rockwell also involved a helicopter crash that arose out of the failure of a part manufactured by SNFA. In Rockwell, the court found that the “cause of action is traced from the sale of the ball bearings by SNFA, through its chain of distribution, to the apparent malfunction that allegedly caused the helicopter to crash…[and therefore] the sale, malfunction and injury all occurred within” the forum state.
Therefore, even though SNFA did not directly sell its part to Air Angels in Illinois, the part ended up in Illinois by way of SNFA’s chain of distribution. The court reasoned that SNFA had manufactured custom bearings with the understanding that parts would find their way into USA-based helicopters. According to the court, this was enough to establish specific jurisdiction in Illinois. And because the “the state in which the injury occurs is then considered to be the state in which the tort occurs,” the court ruled that Illinois has jurisdiction. Accordingly, the Illinois Appellate Court held that dismissal for lack of personal jurisdiction was an error and reversed the lower court.
Kreisman Law Offices has been handling Illinois product defect cases for more than 35 years in and around Chicago, Cook County, and surrounding areas, including Chicago’s Albany Park, Franklin Park, River Grove, Bridgeview, Bedford Park, Orland Park, and Northlake.
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