The First District recently held that the district court had personal jurisdiction over a Texas-based company because of that company’s national advertising scheme and small repeat customer base in Illinois. In Schaefer v. Synergy Flight Center, et al., No. 1-18-1779, Plaintiffs alleged that Defendant RAM Aircraft, L.P., negligently overhauled, repaired, and tested an aircraft’s left engine and other parts, and that the negligent repair caused the aircraft to crash in Illinois, killing its seven passengers. RAM was a Texas-based limited partnership that predominately made its income by overhauling aircraft engines. RAM performed its work in Texas and had no office or property in Illinois. RAM did, however, advertise in a nationally distributed magazine and Illinois customers historically accounted for 1-2.5% of its revenues. The particular engine in question was overhauled by RAM in Texas, who shipped it to a company in Indiana, who then shipped it to an Illinois flight center for installation.
The Court determined that it had specific jurisdiction, or that the Defendant “purposely directed its activities” at Illinois. The court based its holding on the fact that RAM (1) had an ongoing business relationship with six customers in Illinois; (2) received 1% or more of its revenues from Illinois in that year and preceding years; (3) advertised in magazines with national distribution; (4) considered owners of general aviation fleet, including planes based in Illinois, as part of its market; and, (5) the injury occurred within the state. The court also weighed the reasonableness of requiring Defendant to litigate in Illinois, and determined that the burden on RAM of litigating in Illinois did not outweigh the interests of the plaintiff and the state of Illinois, which had an interest in resolving a fatal incident that occurred within its borders. The court gave weight to the fact that RAM’s contact with Illinois was not isolated, and that the company benefitted from the laws of the state as a result of its transactions within the state. Because of these contacts, and because Plaintiffs adequately alleged that RAM’s actions caused the crash in Illinois of an Illinois-based aircraft, the court allowed the litigation to proceed against RAM in Illinois.
While the court’s order was entered under Rule 23(b), and cannot be cited as precedential, companies sued in personal injury and wrongful death cases should be cognizant of the court’s expanding views on personal jurisdiction. Companies should be aware that ongoing business relationships within the state of Illinois, coupled with an advertising scheme that is intended to reach Illinois, could open them up to defending against lawsuits in Illinois that arise from an injury that occurred within the state. This may be true even where, as here, the defendant did not sell the specific product involved in the accident directly to a person or company located in Illinois.
