Rao v. ERA Alaska Airlines

Vijai Rao, Sumathi Mathur, and other Maryland residents (plaintiffs) purchased airline tickets via Expedia.com, an Internet travel website, for a flight from Kodiak, Alaska to Anchorage, Alaska on ERA Alaska Airlines (ERA) (defendant). The plaintiffs traveled from Maryland to Alaska for the intrastate Alaska flight. After deplaning in Anchorage, the plaintiffs noticed that a case containing valuable jewelry and cash was missing. The plaintiffs filed suit in federal district court in Maryland against ERA and other Alaska-based individuals (defendants), alleging negligence and other claims. The defendants moved to dismiss the complaint for lack of personal jurisdiction. The district court denied the defendants’ motion, but allowed the parties to undertake limited discovery to determine whether the defendants had sufficient contacts with Maryland to warrant the exercise of personal jurisdiction over the defendants. Thereafter, the plaintiffs sought to amend their complaint to include facts supporting their argument that the district court possessed personal jurisdiction over the defendants. The defendants opposed the motion to amend and renewed their motion to dismiss, claiming that personal jurisdiction could not attach because ERA had not purposefully engaged in business in Maryland. Rather, ERA argued that it simply allowed the travel website to advertise ERA’s flight information on the system for anyone to access and make a purchase.