Rao v. Era Alaska Airlines

Facts

Plaintiffs purchased airline tickets via Expedia.com, an Internet travel website, for a flight from Kodiak, Alaska to Anchorage, Alaska on  Defendant ERA. The plaintiffs traveled from Maryland to Alaska for the intrastate Alaska flight. After deplaning in Anchorage, Plaintiffs noticed that a case containing valuable jewelry and cash was missing. Plaintiffs filed suit in federal district court in Maryland against Defendants, alleging negligence and other claims. Defendants moved to dismiss the complaint for lack of personal jurisdiction. The district court denied Defendants’ motion, but allowed the parties to undertake limited discovery to determine whether Defendants had sufficient contacts with Maryland to warrant the exercise of personal jurisdiction. Plaintiff moved to amend their complaint to include facts supporting their argument that the district court possessed personal jurisdiction over the defendants. 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.