Smith v. Teledyne Continental Motors, Inc.
840 F. Supp. 2d 927
D.S.C.2012Background
- Jones was killed when a kit-built single-engine plane piloted by Smith crash-landed on Hilton Head after the propeller fell off.
- Jones’s estate, a Georgia citizen, filed suit in South Carolina against Teledyne Continental Motors and other defendants; Lancair International was dismissed by agreement.
- All defendants except Teledyne consented to personal jurisdiction in the Kentucky-based court; Teledyne moved to dismiss for lack of jurisdiction.
- Court ordered discovery on personal jurisdiction; hearing held December 15, 2011; issue ripe for decision.
- Court analyzes long-arm jurisdiction under South Carolina law and due process principles, focusing on Teledyne’s connections to SC.
- Court concludes Teledyne has sufficient SC contacts and that jurisdiction would comport with fair play and substantial justice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Teledyne has specific jurisdiction in SC | Jones argues Teledyne purposefully directed activities in SC. | Teledyne contends contacts are insufficient for jurisdiction. | Yes; specific jurisdiction proper over Teledyne. |
| What test governs jurisdiction post-McIntyre | McIntyre supports stream-of-commerce plus approach. | McIntyre adopts variable approaches; not essential. | Stream-of-commerce plus adopted; supports jurisdiction. |
| Whether Fourth Circuit Lesnick framework applies | Lesnick factors favor SC jurisdiction due to substantial connection and justice concerns. | Not provided, but argues against broad reach. | Lesnick framework applied; jurisdiction sustainable. |
| Would exercise of jurisdiction offend fair play and substantial justice | Strong SC interests and single-forum convenience support jurisdiction. | Harm to Teledyne's interests minimized by forum. | Factors favor SC exercise of jurisdiction. |
Key Cases Cited
- McIntyre Machinery, Ltd. v. Nicastro, 131 S. Ct. 2780 (2011) (stream‑of‑commerce plus test; no majority; ultimately adopts limited form)
- Asahi Metal Industry Co. v. Superior Court, 480 U.S. 102 (1987) (stream of commerce; purposeful direction required for specific jurisdiction)
- World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (1980) (purposeful availment; no forum-related activities defeats jurisdiction)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985) (substantial connection and fair play test for minimum contacts)
- Goodyear Dunlop Tires Operations v. Brown, 131 S. Ct. 2846 (2011) (reiterates distinctions between general and specific jurisdiction; stream-of-commerce context)
- Lesnick v. Hollingsworth & Vose Co., 35 F.3d 945 (4th Cir. 1994) (test for long-arm jurisdiction in product cases: substantial connection and fair play)