Adcock v. SkyHawk Aviation

Background

Justin Adcock, acting as personal representative for the estate of Corey James Adcock and on behalf of Corey James Adcock’s children, brought a diversity case against several defendants. The case concerns a Robinson helicopter that experienced mechanical failure, hit a powerline, and crashed near Elgin, Minnesota, on July 19, 2021. Corey James Adcock was the helicopter’s sole occupant and was fatally injured.

Robinson Helicopter Company manufactured the helicopter and sold it to an Oregon-based dealership in June 2007. Robinson is identified in the opinion as a California company with its principal place of business in Torrance, California.

Motion and jurisdictional discovery

Robinson moved to dismiss the amended complaint for lack of personal jurisdiction, meaning it argued that the federal court could not exercise legal authority over Robinson. The parties agreed that the court did not have general jurisdiction over Robinson. The plaintiffs opposed the motion and requested jurisdictional discovery—limited fact-finding about whether the court had personal jurisdiction.

The court explained that jurisdictional discovery is available when meaningful jurisdictional questions exist, but a plaintiff must offer more than speculative or conclusory assertions. The court found that the plaintiffs had made a sufficient showing at this stage to justify jurisdictional discovery.

Ruling

The court denied Robinson Helicopter Company’s motion to dismiss for lack of jurisdiction and granted the plaintiffs’ request for jurisdictional discovery. The opinion’s narrative describes the motion as denied without prejudice, while the numbered order states that the motion is “DENIED.” The order memorialized rulings the court had already announced from the bench on January 22, 2024.