Russell v. SNFA
408 Ill. App. 3d 827
Ill. App. Ct.2011Background
- Michael Russell died in an Illinois helicopter crash; SNFA manufactured custom tail-rotor bearings for the helicopter model A109.
- PlaintiffJohn Russell, executor of Michael Russell’s estate, sues SNFA alleging a defective bearing caused the crash.
- Bearing replacements in 1998 and 2002 were SNFA bearings, incorporated into Agusta helicopters and distributed globally, including the U.S.
- Plaintiff asserts SNFA’s contacts with Illinois support specific or general jurisdiction; the trial court dismissed for lack of personal jurisdiction.
- The appellate court reverses, holding Illinois has specific jurisdiction under 735 ILCS 5/2-209(a)(2) and (c) and remands for further proceedings.
- Key procedural posture: trial court dismissal for lack of jurisdiction; issue on appeal is whether minimum contacts and due process permit exercise of jurisdiction over SNFA.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Do Illinois courts have jurisdiction over SNFA under 2-209(a)(2)? | Russell argues SNFA’s tortious acts in Illinois and its products’ role in the crash establish minimum contacts. | SNFA contends there are insufficient Illinois contacts to support jurisdiction. | Yes; Illinois has specific jurisdiction under 2-209(a)(2). |
| Does § 2-209(c) (catchall) support jurisdiction given Asahi-like considerations? | § 2-209(c) authorizes jurisdiction to the extent permitted by due process due to defendant’s Illinois-related activities. | Defendant contests that the activities meet due process under § 2-209(c). | Yes; § 2-209(c) supports jurisdiction consistent with due process. |
| Is general jurisdiction under § 2-209(b)(4) applicable? | Plaintiff argues SNFA’s presence in Illinois is continuous and systematic. | SNFA asserts minimal Illinois contacts not amounting to general jurisdiction. | Not reviewed; court found specific jurisdiction sufficient, not necessary to decide general jurisdiction. |
| Are the due process factors (reasonableness) satisfied to permit jurisdiction? | Illinois has an interest in resolving a fatal crash on its soil and protecting its ambulance services. | Litigation burden on an out-of-state defendant and less forum interest. | Yes; reasonableness factors favor Illinois, supporting jurisdiction. |
Key Cases Cited
- Asahi Metal Industry Co. v. Superior Court, 480 U.S. 102 (1987) (minimum contacts and reasonableness framework; indemnification context distinguished)
- Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408 (1984) (minimum contacts and nature of forum state interests)
- Rollins v. Ellwood, 141 Ill.2d 244 (1990) (Illinois due process; balancing factors for jurisdiction)
- Knaus v. Guidry, 389 Ill.App.3d 804 (2009) (minimum contacts and general/specific jurisdiction distinctions)
- Bell v. Don Prudhomme Racing, Inc., 405 Ill.App.3d 223 (2010) (specific jurisdiction and due process; reasonableness analysis)