Katz v. Spiniello Cos.

On May 31, 2014, a Gulfstream G-IV (the plane) crashed in Massachusetts, killing everyone aboard. Drew Katz and Melissa Silver (plaintiffs), the personal representatives of one passenger’s estate, filed suit in Massachusetts and Georgia state courts against many defendants, including Gulfstream Aerospace Corporation (Georgia) (Gulfstream Georgia) (defendant), Gulfstream Aerospace Corporation (Delaware) (Gulfstream Delaware) (defendant), and Gulfstream Aerospace Services Corporation (Gulfstream Services) (defendant) (collectively, the Gulfstream defendants), as well as Rockwell Collins, Inc. (Rockwell) (defendant), alleging in part that the plane’s interlock mechanism and gust-lock system were faulty. The Massachusetts state court case was removed to federal court, and the Gulfstream defendants and Rockwell moved to dismiss for lack of personal jurisdiction. Gulfstream Georgia designed, manufactured, and sold the plane in Georgia. Gulfstream Services serviced the plane in January 2013 with technicians from its Massachusetts facility. Gulfstream Delaware, a holding company, owned both Gulfstream Georgia and Gulfstream Services. None of the Gulfstream defendants were incorporated in Massachusetts. Neither Gulfstream Georgia nor Gulfstream Delaware were registered to do business or had an agent to receive process in Massachusetts. Only Gulfstream Services had a Massachusetts location. Rockwell, a foreign corporation, designed, manufactured, and sold the interlock mechanism and gust lock at issue outside of Massachusetts. Rockwell had not maintained a location in Massachusetts since 2005.