Bryant v. Finnish National Airline

Eleanor Bryant (plaintiff), an employee of Trans World Airlines, was injured by a baggage cart at an airport in Paris. Bryant claimed that an airplane owned by Finnish National Airline (Finnair) (defendant) had blasted excessive air, which caused the baggage cart to strike her. Bryant was a New York resident and sued Finnair in New York state court for her injuries. Finnair was organized in Finland under Finnish law. Finnair’s headquarters were in Finland. Finnair was not registered in the United States, did not have any shareholders, directors, or officers in the United States, did not fly into or from the United States, and was not qualified to do business in New York. However, Finnair maintained offices outside Finland, including a small office in New York. Four full-time and three part-time employees worked in Finnair’s New York office, primarily transmitting reservation requests for European travel to the airline’s Finland-based employees. The New York employees provided some additional limited services for Finnair, such as information, public-relations, and publicity services. However, the New York employees did not complete reservations or sell tickets. Further, the New York office did not have any authority to bind Finnair, and any contracts relating to the New York office had to be approved by Finnair’s headquarters in Finland. The New York office maintained a bank account that it used to pay operating expenses in New York. The account’s average balance was less than $2,000. Finnair moved to dismiss Bryant’s complaint, arguing that it was not subject to personal jurisdiction in New York. The trial court found that Finnair was subject to personal jurisdiction in New York and denied the motion. The appellate division reversed, finding that Finnair was not doing business in New York. The appellate division then held that the New York courts lacked personal jurisdiction over Finnair and ordered the dismissal of Bryant’s lawsuit. Bryant appealed to New York’s highest court.