Duffy v. Kaman Aerospace Corporation, 590 F.Supp.3d 1317

Plaintiffs Mark Duffy (personal representative of Thomas Duffy’s estate) and Central Copters sued Kaman Aerospace after a Kaman-manufactured K-Max helicopter crashed in Oregon on Aug. 24, 2020, alleging defective rotor blades caused the fatal accident.
Kaman moved to dismiss for lack of personal jurisdiction under Fed. R. Civ. P. 12(b)(2) and alternatively to transfer the case to Connecticut under 28 U.S.C. § 1404(a); Plaintiffs opposed.
Central Copters purchased K-Max equipment from Kaman and had a long-standing business relationship: Kaman sales/marketing visits (beginning 1997), delivery of aircraft and parts, on-site service technicians and training in Montana, an exchange-parts program, and involvement in negotiations for later aircraft purchases.
The blades alleged to have failed were sold/shipped by Kaman to Central Copters and installed on the accident helicopter. Central Copters is one of only sixteen K-Max operators worldwide.
Kaman relied on forum-selection clauses in certain documents to seek transfer to Connecticut; Plaintiffs argued those clauses are narrower, inapplicable to the Estate or tort claims, and some were not part of the relevant purchase transaction (and may be contracts of adhesion).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Montana has specific personal jurisdiction over Kaman	Kaman purposefully availed itself of Montana: marketed and sold K-Max aircraft and parts to Central Copters, sent personnel to Montana, delivered blades that allegedly caused the crash, and interjected into negotiations involving Montana-based Central Copters	Kaman had limited contacts: one Montana customer, minimal Montana sales (<1%), core manufacturing and design occurred elsewhere; contacts insufficient for jurisdiction	Court held Montana has specific jurisdiction: Mont. long-arm statute satisfied and due-process factors met (purposeful availment, claim related to in‑state contacts, exercise of jurisdiction reasonable); motion to dismiss denied
Whether forum‑selection clauses and §1404(a) warrant transfer to District of Connecticut	Clauses (where relied upon) are limited to the contract between Kaman and Central Copters, do not bind the Estate or tort claims, some clauses post‑date the subject sale, and the blade purchase was a contract of adhesion; transfer would deprive Plaintiffs of convenient forum	Clauses bind Central Copters and the Estate; parties agreed in advance to litigate in Connecticut, and Connecticut is more convenient	Court held clauses do not mandate transfer: clauses do not bind the Estate or control tort claims here, appear inapplicable or adhesive, and Kaman failed to carry its §1404(a) burden; motion to transfer denied

International Shoe Co. v. Washington, 326 U.S. 310 (established framework for personal jurisdiction analysis)
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (purposeful availment and fair warning for jurisdiction)
Hanson v. Denckla, 357 U.S. 235 (limits on jurisdiction without purposeful contacts)
Ford Motor Co. v. Montana Eighth Jud. Dist. Ct., 141 S. Ct. 1017 (2021) (suit must "arise out of or relate to" forum contacts; a causal-only test is not required)
Keeton v. Hustler Magazine, Inc., 465 U.S. 770 (contacts must not be random or fortuitous)
Bristol-Myers Squibb Co. v. Superior Court, 137 S. Ct. 1773 (limits on jurisdiction where claims lack connection to forum)
Nelson v. San Joaquin Helicopters, 742 P.2d 447 (Mont. 1987) (Montana long-arm application where out‑of‑state defendant transacted business impacting Montana)
Buckles v. Cont'l Res., Inc., 462 P.3d 223 (Mont. 2020) (requirement that suit arise out of or relate to defendant's forum contacts)
Grizzly Sec. Armored Express, Inc. v. Armored Grp., LLC, 255 P.3d 143 (Mont. 2011) (due-process reasonableness inquiry)
Polzin v. Appleway Equip. Leasing, Inc., 191 P.3d 476 (Mont. 2008) (forum‑selection clause unenforceable if not knowingly and voluntarily agreed to; adhesion concerns)
Manetti-Farrow, Inc. v. Gucci Am., Inc., 858 F.2d 509 (9th Cir. 1988) (when forum-selection clauses govern tort claims depends on whether resolution requires contract interpretation)