Herederos de Roberto Gomez Cabrera, LLC v. Teck Resources Ltd.
United States Court of Appeals for the Eleventh Circuit
43 F.4th 1303 (2022)
- Written by Jamie Milne, JD
Facts
Roberto Gomez Cabrera owned mineral mines that were confiscated by the revolutionary Cuban government in 1960. Upon Cabrera’s death, his children inherited his claim to the mines. They assigned that claim to Herederos de Roberto Gomez Cabrera, LLC (Herederos) (plaintiff), a Florida-based company. Herederos sued Teck Resources Ltd. (Teck) (defendant), a Canadian company that managed the mines, arguing that Teck had violated the Helms-Burton Act. The act, which was adopted by Congress in 1996, allowed United States nationals with an interest in property confiscated by the Cuban government to sue foreign companies that trafficked in that property. Teck moved to dismiss the suit, arguing that the United States District Court for the Southern District of Florida lacked personal jurisdiction over Teck. The parties agreed that the Fifth Amendment governed the personal-jurisdiction question but disagreed over the appropriate standard for assessing whether personal jurisdiction existed. Teck argued that the same standard for establishing personal jurisdiction in state court under the Fourteenth Amendment also applied to establishing personal jurisdiction in federal court under the Fifth Amendment. Consequently, Teck argued that its minimum contacts with the forum needed to be sufficient to prevent the suit from offending traditional notions of fair play and substantial justice. Herederos argued that a more lenient standard stemming from extraterritorial-jurisdiction cases applied and the question was therefore merely whether exercising jurisdiction would be arbitrary or fundamentally unfair. The district court held in Teck’s favor and dismissed the suit. Herederos appealed.
Rule of Law
Issue
Holding and Reasoning (Newsom, J.)
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