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United States District Court for the District of Maryland - 22 F. Supp. 3d 529
tl;dr:
An airline company operating out of a single state, who negligently lost a case of jewelry, could not be sued in a separate state even though they sold airlines tickets over the Internet to a customer located there.Video Summary
Case Summary
In the 2014 case of Rao v. Era Alaska Airlines, a group of Maryland residents sued an Alaskan airline and its associated parties over lost personal property during a flight within Alaska. The tickets were purchased through Expedia.com. The airline argued that the Maryland court lacked personal jurisdiction, while the plaintiffs claimed that buying their tickets online granted Maryland jurisdiction.
The court allowed limited discovery to assess whether the airline had sufficient connections to Maryland for exercising jurisdiction. After discovery, the plaintiffs attempted to amend their complaint, but the defendants reiterated their argument of lacking essential contacts in Maryland. The court ultimately agreed with the defendants, dismissing the case for lack of personal jurisdiction.
The court held that simply having a passive website through which tickets were bought was not enough to establish required contacts with Maryland. Moreover, the plaintiffs' claims were not directly related to the airline's activities in Maryland. Exercising jurisdiction would be unreasonable and unfair in such a situation.
This case highlighted that not all online activities create sufficient connections for personal jurisdiction. Courts must consider various factors in order to determine whether jurisdiction is appropriate under due process. The case also demonstrated the differing approaches of federal and state courts in applying personal jurisdiction in cases involving online transactions.
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The Maryland Plaintiffs are suing an Alaska-based airline and other Alaska Defendants for torts related to the loss of personal property on a flight operated by the airline. The defendants moved to dismiss the case for lack of personal jurisdiction, arguing that the claims arose from a flight within Alaska operated by an airline that only transacts business within Alaska. The District Judge found that Maryland cannot exercise personal jurisdiction over Defendants, but the interests of justice require the case to be transferred to the U.S. District Court for the District of Alaska. The plaintiffs allege negligence, breach of implied warranty, fraud, violation of aviation consumer protection, gross negligence, and punitive damages after losing valuable personal property. The issue at hand is personal jurisdiction, and the defendants have opposed the plaintiffs' motion to amend the complaint. To challenge personal jurisdiction, the plaintiff must prove grounds for jurisdiction by a preponderance of the evidence. Personal jurisdiction can be either general or specific, and both require the defendant to purposefully avail itself of the privilege of conducting activities within the forum state. The court must analyze whether the exercise of jurisdiction is authorized under the state's long-arm statute and whether it comports with the due process requirements of the Fourteenth Amendment. The complaint must identify the specific statutory provision that authorizes jurisdiction, and the plaintiff's claims must arise from an act enumerated in the Maryland long-arm jurisdiction statute to exercise jurisdiction. In this case, the plaintiffs are relying on two provisions to establish personal jurisdiction over the defendant, ERA Alaska Airlines, but personal jurisdiction cannot be established under one of the provisions because ERA did not contract to supply any goods or services in Maryland. The lower court erred in finding personal jurisdiction over the defendants, and the case must be transferred to the U.S. District Court for the District of Alaska.
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