Service Of Process On Foreign Corporation.

After a plane crashed in Cuba, killing everyone on board, the family of one of the decedents sued the French corporation which designed and manufactured the airplane in federal court in California. Plaintiffs served the summons and complaint at the corporate headquarters in France, and the corporation moved to dismiss for lack of personal jurisdiction. After the trial court permitted plaintiff to conduct limited jurisdictional discovery, and prior to the scheduled hearing, plaintiff served copies of the summons and complaint on the corporation’s vice-president while he was attending a conference in California on the corporation’s behalf. The district court granted the motion to dismiss. The Ninth Circuit affirmed, stating: “We hold that Burnham [Burnham v. Sup. Ct. (1990) 495 U.S. 604, [110 S.Ct. 2105, 109 L.Ed.2d 631], does not apply to corporations. A court may exercise general personal jurisdiction over a corporation only when its contacts ‘render it essentially at home’ in the state. . . Because [the corporation here] is not otherwise ‘essentially at home’ in California, and service on its corporate officer did not render it so, we affirm the district court.”  (Martinez v. Aero Caribbean (Ninth Cir.; August 21, 2014) 764 F.3d 1062.)