Khan v. Qatar Airways Corporation, 4:23-cv-04138

Mariam Khan, a Texas resident, alleges that during a stopover in Doha, Qatar, she was involuntarily subjected to an invasive gynecological search by Qatari police, assisted by Qatar Airways staff, after a newborn was found abandoned at the airport.
The incident occurred as part of Khan’s roundtrip flight on Qatar Airways between Texas and Pakistan in October 2020.
Khan originally filed suit in Illinois state court; it was removed to federal court in Illinois, where the court both dismissed the complaint without prejudice and ordered transfer to the Southern District of Texas due to lack of personal jurisdiction in Illinois.
Khan filed an amended complaint in the Southern District of Texas, asserting common law personal injury and Montreal Convention claims against Qatar Airways.
Qatar Airways moved to dismiss on grounds of lack of personal jurisdiction, untimeliness, and forum non conveniens.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Specific Personal Jurisdiction	Qatar Airways has sufficient contacts with Texas.	The only connection is Khan's Texas ticket purchase.	Texas has specific jurisdiction; claim "relates to" defendant’s Texas business.
Timeliness of Claims	Transfer, not dismissal, controls limitations period.	The case was dismissed, so refiling is time-barred.	Court treats prior action as transfer (not dismissal); claims are timely.
Forum Non Conveniens	Qatar is not an adequate or available forum.	Qatar is available, adequate, and more convenient.	Qatar is available and adequate, but private/public interest factors do not favor dismissal.
Applicability of Foreign Law (Count I)	Should apply U.S. law to personal injury claim.	Qatari law governs as events occurred in Qatar.	Qatari law applies to Count I; leave to amend granted.

Bell Atl. Corp. v. Twombly, 550 U.S. 544 (motion to dismiss standard requires claim to be plausible, not just possible)
Ashcroft v. Iqbal, 556 U.S. 662 (legal conclusions not assumed true at motion to dismiss)
Piper Aircraft Co. v. Reyno, 454 U.S. 235 (standard for adequacy of alternative forum in forum non conveniens)
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (compelling reason required to find jurisdiction improper once minimum contacts shown)
Ford Motor Co. v. Montana Eighth Jud. Dist. Ct., 592 U.S. 351 ("relate to" prong in specific jurisdiction analysis)
Koster v. (American) Lumbermens Mut. Casualty Co., 330 U.S. 518 (test for forum non conveniens is convenience and justice)
Stroman Realty, Inc. v. Antt, 528 F.3d 382 (Texas long-arm jurisdiction extends to constitutional limits)
Luv N’ care, Ltd. v. Insta–Mix, Inc., 438 F.3d 465 (plaintiff must make prima facie showing for personal jurisdiction)