Pacific Reliant Industries, Inc. v. Amerika Samoa Bank

Pacific Reliant Industries, Inc., an Oregon corporation, sued the Amerika Samoa Bank, an America Samoa corporation, for failure to honor a letter of credit. The District Court for the District of Oregon dismissed the suit for lack of personal jurisdiction. We affirm.

FACTS

Pacific Reliant Industries, Inc., (“Pacific”), sold building materials to Paradise Development Company, (“Paradise”), an American Samoa company owned and managed by Malua Hunkin. Pacific was reluctant to make several large deliveries, totaling more than one million dollars, without some protection against nonpayment or late payment. Hunkin sought a letter of credit from the Amerika Samoa Bank, (“ASB”). Representatives from Pacific, Paradise, and ASB met in American Samoa on two occasions to discuss the supply contract and the letter of credit. ASB issued an irrevocable standby letter of credit in favor of Pacific for up to $300,000 on Paradise’s account. A few months later, an amendment to the letter of credit extended the expiration date. The first letter of credit was delivered to Pacific’s representative in American Samoa. The amended letter of credit was either delivered in American Samoa or mailed to…