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27 Texas opinions name it 3 courts 2007–2023 1 in the last five years
The cases below were cited by Texas courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Quixtar Inc. v. Signature Management Team, LLCgreen2 sentences2015“The well-known Gulf Oil factors direct courts to consider both public and private interest considerations in forum non conveniens dismissals.” 315 S.W.3d at 33 (citing Gulf Oil, 330 U.S. at 508–09). 2015“The well-known Gulf Oil factors direct courts to consider both public and private interest considerations in forum non conveniens dismissals.” 315 S.W.3d at 33 (citing Gulf Oil, 330 U.S. at 508–09). | 7 | 13 |
In Re Pirelli Tire, L.L.C.green2 sentences2019See In re Pirelli Tire, 247 S.W.3d 670, 677 (Tex. 2007) (“[t]he Gulf Oil factors presuppose that an adequate alternative forum would have jurisdiction over the case”) (citing Gulf Oil v. Gilbert, 330 U.S. 501, 507 , 67 S.Ct. 839 (1947)); In re Elamex, 367 S.W.3d at 887 (“[b]ecause the common law doctrine of forum non conveniens presumes that at least two forums are available to a plaintiff, a trial court must first determine whether an alternative forum exists, inquiring whether another forum is ‘available’ and ‘adequate’”) (emphasis added), accord Daniels, 538 S.W.3d at 147 ; Grynberg v. Gryn 2019See In re Pirelli Tire, 247 S.W.3d 670, 677 (Tex. 2007) (“[t]he Gulf Oil factors presuppose that an adequate alternative forum would have jurisdiction over the case”) (citing Gulf Oil v. Gilbert, 330 U.S. 501, 507 , 67 S.Ct. 839 (1947)); In re Elamex, 367 S.W.3d at 887 (“[b]ecause the common law doctrine of forum non conveniens presumes that at least two forums are available to a plaintiff, a trial court must first determine whether an alternative forum exists, inquiring whether another forum is ‘available’ and ‘adequate’”) (emphasis added), accord Daniels, 538 S.W.3d at 147 ; Grynberg v. Gryn | 6 | 7 |
Gulf Oil Corp. v. Gilbertred2 sentences2019See In re Pirelli Tire, 247 S.W.3d 670, 677 (Tex. 2007) (“[t]he Gulf Oil factors presuppose that an adequate alternative forum would have jurisdiction over the case”) (citing Gulf Oil v. Gilbert, 330 U.S. 501, 507 , 67 S.Ct. 839 (1947)); In re Elamex, 367 S.W.3d at 887 (“[b]ecause the common law doctrine of forum non conveniens presumes that at least two forums are available to a plaintiff, a trial court must first determine whether an alternative forum exists, inquiring whether another forum is ‘available’ and ‘adequate’”) (emphasis added), accord Daniels, 538 S.W.3d at 147 ; Grynberg v. Gryn 2019See In re Pirelli Tire, 247 S.W.3d 670, 677 (Tex. 2007) (“[t]he Gulf Oil factors presuppose that an adequate alternative forum would have jurisdiction over the case”) (citing Gulf Oil v. Gilbert, 330 U.S. 501, 507 , 67 S.Ct. 839 (1947)); In re Elamex, 367 S.W.3d at 887 (“[b]ecause the common law doctrine of forum non conveniens presumes that at least two forums are available to a plaintiff, a trial court must first determine whether an alternative forum exists, inquiring whether another forum is ‘available’ and ‘adequate’”) (emphasis added), accord Daniels, 538 S.W.3d at 147 ; Grynberg v. Gryn | 4 | 12 |
In Re General Electric Co.green2 sentences2009Pirelli Tires, 247 S.W.3d at 675-77 (discussing Gulf Oil, 330 U.S. at 508 )); see also General Elec., 271 S.W.3d at 689, 691-92 (applying Gulf Oil factors when analyzing statutory factors of whether maintaining the claim in Texas would work a “substantial injustice to the moving party,” Tex. Civ. 2009Code Ann. § 71.051 (b)(3), and whether “the balance of the private interests of the parties and the public interest of the state predominate in favor of the claim or action being brought in an alternative forum,” id. § 71.053(b)(5)).2 In fact, General Electric’s holdings regarding the movant’s burden as to its access to out-of-state witnesses and evidence were stated in terms of the Gulf Oil factors. 271 S.W.3d at 689-92 . | 2 | 3 |
Direct Color Services, Inc. v. Eastman Kodak Co.green2 sentences2019See In re Pirelli Tire, 247 S.W.3d 670, 677 (Tex. 2007) (“[t]he Gulf Oil factors presuppose that an adequate alternative forum would have jurisdiction over the case”) (citing Gulf Oil v. Gilbert, 330 U.S. 501, 507 , 67 S.Ct. 839 (1947)); In re Elamex, 367 S.W.3d at 887 (“[b]ecause the common law doctrine of forum non conveniens presumes that at least two forums are available to a plaintiff, a trial court must first determine whether an alternative forum exists, inquiring whether another forum is ‘available’ and ‘adequate’”) (emphasis added), accord Daniels, 538 S.W.3d at 147 ; Grynberg v. Gryn 2019See In re Pirelli Tire, 247 S.W.3d 670, 677 (Tex. 2007) (“[t]he Gulf Oil factors presuppose that an adequate alternative forum would have jurisdiction over the case”) (citing Gulf Oil v. Gilbert, 330 U.S. 501, 507 , 67 S.Ct. 839 (1947)); In re Elamex, 367 S.W.3d at 887 (“[b]ecause the common law doctrine of forum non conveniens presumes that at least two forums are available to a plaintiff, a trial court must first determine whether an alternative forum exists, inquiring whether another forum is ‘available’ and ‘adequate’”) (emphasis added), accord Daniels, 538 S.W.3d at 147 ; Grynberg v. Gryn | 2 | 2 |
In Re ELAMEX, S.A. De C v. Elamex USA, Corp., and Mount Franklin Foods, L.L.Cgreen2 sentences2019See In re Pirelli Tire, 247 S.W.3d 670, 677 (Tex. 2007) (“[t]he Gulf Oil factors presuppose that an adequate alternative forum would have jurisdiction over the case”) (citing Gulf Oil v. Gilbert, 330 U.S. 501, 507 , 67 S.Ct. 839 (1947)); In re Elamex, 367 S.W.3d at 887 (“[b]ecause the common law doctrine of forum non conveniens presumes that at least two forums are available to a plaintiff, a trial court must first determine whether an alternative forum exists, inquiring whether another forum is ‘available’ and ‘adequate’”) (emphasis added), accord Daniels, 538 S.W.3d at 147 ; Grynberg v. Gryn 2019See In re Pirelli Tire, 247 S.W.3d 670, 677 (Tex. 2007) (“[t]he Gulf Oil factors presuppose that an adequate alternative forum would have jurisdiction over the case”) (citing Gulf Oil v. Gilbert, 330 U.S. 501, 507 , 67 S.Ct. 839 (1947)); In re Elamex, 367 S.W.3d at 887 (“[b]ecause the common law doctrine of forum non conveniens presumes that at least two forums are available to a plaintiff, a trial court must first determine whether an alternative forum exists, inquiring whether another forum is ‘available’ and ‘adequate’”) (emphasis added), accord Daniels, 538 S.W.3d at 147 ; Grynberg v. Gryn | 2 | 2 |
Piper Aircraft Co. v. Reynogreen2 sentences2011See id. 2011See id. | 2 | 2 |
Adams v. ESC MEDICAL SYSTEMS, INC.green2 sentences2010Sys., Inc. , 161 S.W.3d 49, 50 (Tex. App.—Houston [14th Dist.] 2004, no pet.) (“Unless the balance of factors strongly favors the defendant, the plaintiff’s choice of forum should rarely be disturbed.”). 2010Sys., Inc. , 161 S.W.3d 49, 50 (Tex. App.—Houston [14th Dist.] 2004, no pet.) (“Unless the balance of factors strongly favors the defendant, the plaintiff’s choice of forum should rarely be disturbed.”). | 2 | 2 |
SIGNATURE MANAGEMENT TEAM, LLC v. Quixtar, Inc.green2 sentences2010Team, LLC v. Quixtar, Inc. , 281 S.W.3d 666, 675 (Tex. App.—Dallas 2009, pet. filed) (“Quixtar’s burden was to show that the Gulf Oil factors in their totality strongly favor dismissal.”); Adams v. ESC Med. 2010Team, LLC v. Quixtar, Inc. , 281 S.W.3d 666, 675 (Tex. App.—Dallas 2009, pet. filed) (“Quixtar’s burden was to show that the Gulf Oil factors in their totality strongly favor dismissal.”); Adams v. ESC Med. | 2 | 2 |
RSR Corp. v. Siegmundgreen2 sentences2023RSR Corp. v. Siegmund, 309 S.W.3d 686, 710 (Tex. App.—Dallas 2010, no pet.) (citing Gulf Oil, 330 U.S. at 508–09). 2017RSR Corp., 309 S.W.3d at 710 (citing Gulf Oil, 330 U.S. at 509 , 67 S.Ct. 839 ). | 1 | 2 |
In Re Smith Barney, Inc.green1 sentence2016See Gulf Oil Corp. v. Gilbert, 330 U.S. 501, 508-09 (1947); In re Smith Barney, Inc., 975 S.W.2d 593, 596 (Tex. 1998) ("We embraced Gulf Oil's analysis long ago."). | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Texas. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Terrence L. Daniels v. Barbara Browder, Susana Martinez, in Her Individual and Official Capacities, Amy Orlando, in Her Individual and Official Capacities, Susan Riedel, in Her Individual and Official Capacities, James Dickens, in His Individual and Official Capacities
green
2 sentences2019See In re Pirelli Tire, 247 S.W.3d 670, 677 (Tex. 2007) (“[t]he Gulf Oil factors presuppose that an adequate alternative forum would have jurisdiction over the case”) (citing Gulf Oil v. Gilbert, 330 U.S. 501, 507 , 67 S.Ct. 839 (1947)); In re Elamex, 367 S.W.3d at 887 (“[b]ecause the common law doctrine of forum non conveniens presumes that at least two forums are available to a plaintiff, a trial court must first determine whether an alternative forum exists, inquiring whether another forum is ‘available’ and ‘adequate’”) (emphasis added), accord Daniels, 538 S.W.3d at 147 ; Grynberg v. Gryn 2019See In re Pirelli Tire, 247 S.W.3d 670, 677 (Tex. 2007) (“[t]he Gulf Oil factors presuppose that an adequate alternative forum would have jurisdiction over the case”) (citing Gulf Oil v. Gilbert, 330 U.S. 501, 507 , 67 S.Ct. 839 (1947)); In re Elamex, 367 S.W.3d at 887 (“[b]ecause the common law doctrine of forum non conveniens presumes that at least two forums are available to a plaintiff, a trial court must first determine whether an alternative forum exists, inquiring whether another forum is ‘available’ and ‘adequate’”) (emphasis added), accord Daniels, 538 S.W.3d at 147 ; Grynberg v. Gryn | 2 | 2018–2019 |
Grynberg v. Grynberg
green
2 sentences2019See In re Pirelli Tire, 247 S.W.3d 670, 677 (Tex. 2007) (“[t]he Gulf Oil factors presuppose that an adequate alternative forum would have jurisdiction over the case”) (citing Gulf Oil v. Gilbert, 330 U.S. 501, 507 , 67 S.Ct. 839 (1947)); In re Elamex, 367 S.W.3d at 887 (“[b]ecause the common law doctrine of forum non conveniens presumes that at least two forums are available to a plaintiff, a trial court must first determine whether an alternative forum exists, inquiring whether another forum is ‘available’ and ‘adequate’”) (emphasis added), accord Daniels, 538 S.W.3d at 147 ; Grynberg v. Gryn 2019See In re Pirelli Tire, 247 S.W.3d 670, 677 (Tex. 2007) (“[t]he Gulf Oil factors presuppose that an adequate alternative forum would have jurisdiction over the case”) (citing Gulf Oil v. Gilbert, 330 U.S. 501, 507 , 67 S.Ct. 839 (1947)); In re Elamex, 367 S.W.3d at 887 (“[b]ecause the common law doctrine of forum non conveniens presumes that at least two forums are available to a plaintiff, a trial court must first determine whether an alternative forum exists, inquiring whether another forum is ‘available’ and ‘adequate’”) (emphasis added), accord Daniels, 538 S.W.3d at 147 ; Grynberg v. Gryn | 2 | 2018–2019 |
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.