Lorenzo Mendoza Martinez v. Avions De Transport Regional

Plaintiffs, the heirs of Lorenzo Corazon Mendoza Cervantes, appeal the district court’s dismissal of their claims against Avions de Transport Régional (“ATR”) for lack of personal jurisdiction. Cervantes was a passenger on an airplane that crashed in Cuba, killing everyone aboard. ATR, a French company, designed and manufactured the airplane. Plaintiffs sued ATR in federal court in California, alleging that ATR’s defective design and construction of the airplane caused the crash.

We must decide whether, under Burnham, v. Superior Court, 495 U.S. 604 , 110 S.Ct. 2105 , 109 L.Ed.2d 631 (1990), service of process on a corporation’s officer within the forum state creates general personal jurisdiction over the corporation. We hold that Burnham does not apply to corporations. A court may exercise general personal jurisdiction over a corporation only when its contacts “render it essentially at home” in the state. Daimler AG v. Bauman, — U.S. -, 134 S.Ct. 746, 751 , 187 L.Ed.2d 624 (2014) (alteration and internal quotation marks omitted). Because ATR is not otherwise “essentially at home” in California, and service on its corporate officer did not render it so, we affirm the…