Russell v. SNFA
2013 IL 113909
| Ill. | 2013Background
- This is a products-liability case arising from a fatal Illinois helicopter crash involving SNFA’s custom tail-rotor bearing.
- Plaintiff, the estate of Michael Russell, alleges strict liability and negligence against SNFA and related aerospace defendants.
- SNFA supplied bearings to Agusta, which manufactured helicopters; AAC (Agusta’s U.S. distributor) sold SNFA bearings and helicopter components in the United States, including Illinois.
- Discovery showed SNFA had no Illinois offices, assets, or employees, but did have a distribution network through Agusta and AAC and a business relationship with Hamilton Sundstrand in Rockford, Illinois.
- The circuit court dismissed for lack of personal jurisdiction; the appellate court reversed; this court affirmed, clarifying the application of McIntyre, Asahi, and related stream-of-commerce doctrine.
- The court held that SNFA’s minimum contacts with Illinois exist under a stream-of-commerce theory via Agusta/AAC and through a Rockford-based Hamilton Sundstrand relationship, making Illinois a reasonable forum.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Illinois may exercise specific jurisdiction over SNFA | SNFA has minimum contacts; its bearings reached Illinois via Agusta/AAC and Rockford operations related to the accident. | No Illinois-specific activity; SNFA lacks the purposeful availment and stream-of-commerce connection to Illinois. | Yes; Illinois may exercise specific jurisdiction |
| Whether SNFA is subject to general jurisdiction in Illinois | SNFA’s continuous and systemic contacts render Illinois home for general jurisdiction. | SNFA has no ongoing presence or substantial activities in Illinois. | No general jurisdiction |
| Application of the stream-of-commerce theory to SNFA's contacts | Agusta/AAC’s role as distributor and SNFA’s Illinois-related sales show purposeful availment. | A single or mere market presence through distributors is insufficient without targeted conduct. | Sustained; stream-of-commerce with something more present |
| Whether SNFA had Illinois-specific activity sufficient under McIntyre/Brennan/Narrow theory | There was Illinois-focused activity via Hamilton Sundstrand Rockford interactions and Illinois-based sales. | No Illinois-specific design, advertising, or purposeful targeting; contacts are too indirect. | Yes, under narrow approach with Illinois-specific activity |
| Whether imposing Illinois jurisdiction is reasonable considering burden and interests | Illinois has strong interest; plaintiff resided and worked there and the crash occurred there. | Significant burden on a French manufacturer; potentially unfair forum. | Yes, jurisdiction reasonable |
Key Cases Cited
- World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (U.S. 1980) (stream-of-commerce and minimum contacts framework)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (U.S. 1985) (purposeful availment and fair-play analysis)
- Asahi Metal Industry Co. v. Superior Court, 480 U.S. 102 (U.S. 1987) (three opinions on stream-of-commerce; a guiding split in applying minimum contacts)
- Rockwell International Corp. v. Costruzioni Aeronautiche Giovanni Agusta, S.p.A., 553 F. Supp. 328 (E.D. Pa. 1982) (early case recognizing distributor-relationship as purposeful availment for stream-of-commerce)
- Wiles v. Morita Iron Works Co., 125 Ill. 2d 144 (Ill. 1988) (Illinois standard requiring awareness that final product is marketed in forum state)
- McIntyre Machinery, Ltd. v. Nicastro, 131 S. Ct. 2780 (U.S. 2011) (plurality and multiple opinions on stream-of-commerce and minimum contacts)
- Rollins v. Ellwood, 141 Ill. 2d 244 (Ill. 1990) (long-arm statute analysis; separation of statutory and due process inquiries in some contexts)
- Hyatt International Corp. v. Coco, 302 F.3d 707 (7th Cir. 2002) (principles of long-arm statute and due process in Seventh Circuit)
- Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915 (U.S. 2011) (general jurisdiction framework (note: reporter citation provided for completeness))