Submersible Systems, Inc. v. Perforadora Central, S.A. de C.V.

249 F.3d 413, 2001 AMC 1873 (2001)

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Submersible Systems, Inc. v. Perforadora Central, S.A. de C.V.

United States Court of Appeals for the Fifth Circuit
249 F.3d 413, 2001 AMC 1873 (2001)

Facts

Submersible Systems, Inc. (SSI) (plaintiff) operated submersible vehicles for underwater construction and inspections. SSI contracted with Quantum Ingenieros, S.A. de C.V. (Quantum), to provide submersibles for Quantum’s work on oil pipelines in Mexican waters. Quantum chartered with Perforadora Central, S.A. de C.V. (Central) (defendant) to transport equipment and personnel, including SSI’s submersibles and employees, to the pipeline location. When Quantum failed to pay its contractors on time, Central terminated that charter and brought its vessel into port in Mexico. Central’s employees on the vessel reported SSI’s employees to the Mexican authorities for immigration violations and confiscated SSI’s equipment. Central refused to release the equipment back to SSI and filed legal proceedings in Mexico alleging that the equipment belonged not to SSI but to Quantum. Central eventually released the equipment back to SSI, but due to prolonged exposure to the elements, the equipment was ruined. SSI filed suit in federal district court in Mississippi against Central for the conversion of its equipment. Central moved to dismiss the suit for lack of personal jurisdiction. Central at the time of the suit was building a marine drilling rig in Mississippi and had an office with three employees monitoring that construction, but otherwise it did not have contacts in the state. The district court ruled that Central’s contacts with Mississippi were sufficient for Central to be subject to the suit. The court found that Central had converted SSI’s equipment and awarded SSI compensatory and punitive damages. Central appealed.

Rule of Law

Issue

Holding and Reasoning (Davis, J.)

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