Rao v. ERA Alaska Airlines Case Brief Summary | Law Case Explained

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Rao v. ERA Alaska Airlines, 22 F. Supp. 3d 529 (2014)
A court can exercise personal jurisdiction over a nonresident defendant who maintains minimum contacts with the forum state. But what if the defendant and the forum state were only brought together by business transacted on the Internet? In Rao versus Era Alaska Airlines, the Alaska based defendant argues that an online booking can’t subject it to jurisdiction in Maryland.
In 2010, the Internet brought together two Maryland based passengers and an Alaskan airline. Vijai Rao and Sumathi Mathur used the travel website Expedia to book tickets for a flight with Era Airlines. The pair traveled to Alaska and boarded an Era flight from Kodiak to Anchorage. On the flight, they had a case full of jewelry and cash. Rao and Mathur arrived in Anchorage, but the case didn’t.
Rao and Mathur sued Era for negligence and other claims. They filed their complaint in a Maryland federal court. Era claimed that it didn’t have minimum contacts with Maryland such that the court could subject it to personal jurisdiction. Era was based and operated in Alaska. All Era flights departed from and landed at Alaskan airports. And Era advertised on local newspapers’ websites, which were directed at Alaskan residents.
The passengers relied on Era’s web presence, which had enabled them to book tickets from Maryland. Era had a website and marketed its tickets online through a company called Sabre. Customers could book Era flights using Sabre websites, including Travelocity and Expedia. Moreover, Sabre had a physical office in Maryland. The passengers claimed that these facts established personal jurisdiction. Era disagreed and filed a motion to dismiss.
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