general jurisdiction inquiry in Texas

2025The general-jurisdiction inquiry is “very different from a specific 11 jurisdiction inquiry” and involves a “more demanding minimum contacts analysis” with a “substantially higher threshold.” PHC-Minden, 235 S.W.3d at 167–68 (citations omitted).

2025The general-jurisdiction inquiry is “very different from a specific jurisdiction inquiry” and involves a “more demanding minimum contacts analysis” with a “substantially higher threshold.” PHC-Minden, 235 S.W.3d at 167–68 (citations omitted).

2018Because general jurisdiction permits a court to exercise personal jurisdiction over a nonresident for claims not directly linked to the defendant’s contacts with the state, a general jurisdiction inquiry requires “a ‘more demanding minimum contacts analysis,’ with a ‘substantially higher’ threshold[.]” PHC–Minden, 235 S.W.3d at 168 (quoting CSR Ltd. v. Link, 17 925 S.W.2d 591, 595 (Tex. 1996) and 4 CHARLES ALAN WRIGHT & ARTHUR R.

2018Because general jurisdiction permits a court to exercise personal jurisdiction over a nonresident for claims not directly linked to the defendant’s contacts with the state, a general jurisdiction inquiry requires “a ‘more demanding minimum contacts analysis,’ with a ‘substantially higher’ threshold[.]” Id. at 168 (quoting CSR Ltd. v. Link, 925 S.W.2d 591, 595 (Tex. 1996) and 4 CHARLES ALAN WRIGHT & ARTHUR R.

2007See Experimental Aircraft Assoc., Inc., 76 S.W.3d at 506-07 .

2007See Experimental Aircraft Ass’n, Inc., 76 S.W.3d at 507 .

2025While a corporation may be at home in other locations “in an exceptional case,” the general jurisdiction inquiry “calls for an appraisal of a corporation’s activities in their entirety, nationwide and worldwide” because “[a] corporation that operates in many places can scarcely be deemed at home in all of them.” Id. at 139 n.19, 20. “[T]he ties between the litigation itself and the forum state are irrelevant to the question of whether general jurisdiction exists.” Searcy, 496 S.W.3d at 72 . “[G]eneral jurisdiction relies on the defendant itself being tied up—almost entangled in a web—with the

2024The general jurisdiction inquiry “calls for an appraisal of a corporation’s activities in their entirety” because “[a] corporation that operates in many places can scarcely be deemed at home in all of them.” Daimler AG, 571 U.S. at 139 n.20, 134 S. Ct. at 762 n.20. 2.

2020“A general jurisdiction inquiry can be tedious, as it ‘demands . . . . that all contacts be carefully investigated, compiled, sorted, and analyzed for proof of a pattern of continuing and systematic activity.’” Id. at 170 (quoting Schlobohm v. Schapiro, 784 S.W.2d 355, 359 (Tex. 1990)).

2015A general jurisdiction inquiry can be tedious, as it “demands ... that all contacts be carefully investigated, compiled, sorted, and analyzed for proof of a pattern of continuing and systematic activity.” Schlobohm v. Schapiro, 784 S.W.2d 355, 359 (Tex.1990).

2016Rather, general jurisdiction relies on the defendant itself being tied up—almost entangled in a web—with the forum state.70 Thus, subsidiaries that are totally unrelated to the forum state, 64 Id. 65 Keeton v. Hustler Magazine, Inc., 465 U.S. 770 , 780 n.11 (1984). 66 466 U.S. 408 (1984). 67 Id. at 416 . 68 Id. at 410 . 69 Id. at 418 . 70 See, e.g., International Shoe Co. v. Washington, 326 U.S. 310, 318 (1945). 19 its economy, and its laws, cannot be haled into that state’s courts merely by virtue of their ownership, and their ownership alone.71 And more recent Supreme Court cases have clarif

2016Rather, general jurisdiction relies on the defendant itself being tied up—almost entangled in a web—with the forum state.70 Thus, subsidiaries that are totally unrelated to the forum state, 64 Id. 65 Keeton v. Hustler Magazine, Inc., 465 U.S. 770 , 780 n.11 (1984). 66 466 U.S. 408 (1984). 67 Id. at 416 . 68 Id. at 410 . 69 Id. at 418 . 70 See, e.g., International Shoe Co. v. Washington, 326 U.S. 310, 318 (1945). 19 its economy, and its laws, cannot be haled into that state’s courts merely by virtue of their ownership, and their ownership alone.71 And more recent Supreme Court cases have clarif

2025See Goodyear, 564 U.S. at 919, 924 ; Volkswagen, 669 S.W.3d at 412; see In Perkins, the defendant admittedly and indisputably moved also Grupo Mex., 2020 WL 486501 , at *4.

2018See Daimler, 134 S. Ct. at 761 (quoting Goodyear, 564 U.S. at 919 ).

2011In a general jurisdiction analysis, we do not view each contact in isolation, but instead investigate, compile, sort, and analyze all contacts “for proof of a pattern of continuing and systematic activity.” Id. at 809 .

2011In a general jurisdiction analysis, we do not view each contact in isolation, but instead investigate, compile, sort, and analyze all contacts “for proof of a pattern of continuing and systematic activity.” Id. at 809 .

2007Revell v. Lidov, 317 F.3d 467, 471 (5th Cir.2002).

2007Revell, 317 F.3d at 471 .

2010See BMC Software , 83 S.W.3d at 797 .

2010See BMC Software, 83 S.W.3d at 797 . 8 Steele contends that the issuance of CertaLogic preferred stock to an investor in August 2006 made Steele’s stock “obsolete.” Even if this is true, there is no evidence or allegation that any of CertaLogic’s officers approved or were otherwise involved with such issuance.

2025Even if a defendant maintains continuous and systematic contacts with the forum state, those contacts “are insufficient to confer general jurisdiction if they fail to rise to the level of rendering [the] defendant essentially at home in the forum state.” Old Republic, 549 S.W.3d at 565 (emphasis in original, internal quotation marks omitted); see also Baldaramos v. Metamorphosis Consulting, LLC, No. 04-19-00356-CV, 2019 WL 6719033 , at *4 (Tex. App.—San Antonio Dec. 11, 2019, no pet.) (mem. op.).

2020Even if a defendant maintains continuous and systematic contacts with the forum state, those contacts “are insufficient to confer general jurisdiction if they fail to rise to the level of rendering [the] defendant essentially at home in the forum state.” Old Republic, 549 S.W.3d at 565 (emphasis in original, internal quotation marks omitted); see also Baldaramos v. Metamorphosis Consulting, LLC, No. 04-19-00356-CV, 2019 WL 6719033 , at *4 (Tex. App.—San Antonio Dec. 11, 2019, no pet.).

2015Usually, “the defendant must be engaged in longstanding business in the forum state, such as marketing or shipping products, or performing services or maintaining one or more offices there; activities that are less extensive than that will not qualify for general in personam jurisdiction.” 4 WRIGHT & MILLER, FEDERAL PRACTICE & PROCEDURE § 1067.5; see also Hall, 638 S.W.2d at 882 (Pope, J., dissenting) (noting that “substantial and continuous activity” required for general jurisdiction suggests that defendant “must establish some close substantial connection with the state approaching the relat

2007Usually, “the defendant must be engaged in longstanding business in the forum state, such as marketing or shipping products, or performing services or maintaining one or more offices there; activities that are less extensive than that will not qualify for general in personam jurisdiction.” 4 Wright & MilleR, Federal PRACTICE & PROCEDURE § 1067.5; see also Hall, 638 S.W.2d at 882 (Pope, J., dissenting) (noting that “substantial and continuous activity” required for general jurisdiction suggests that defendant “must establish some close substantial connection with the state approaching the relat

2006For example, appellants cite the Texas Supreme Court’s statement in National Industrial Sand Ass’n v. Gibson, 897 S.W.2d 769, 774 (Tex.1995), that “[a]n organization that mails national newsletters and notices of acceptance of dues to a member company in Texas has not purposefully established minimum contacts such that it could reasonably foresee being sued in the courts of this State.” However, this statement was made in the context of a general jurisdiction analysis, and has no application to the facts supporting the exercise of specific jurisdiction in this case.

2005For example, appellants cite the Texas Supreme Court’s statement in National Industrial Sand Ass’n v. Gibson , 897 S.W.2d 769, 774 (Tex. 1995) , that “[a]n organization that mails national newsletters and notices of acceptance of dues to a member company in Texas has not purposefully established minimum contacts such that it could reasonably foresee being sued in the courts of this State.” However, this statement was made in the context of a general jurisdiction analysis, and has no application to the facts supporting the exercise of specific jurisdiction in this case.

2006Another case cited by appellants, U-Anchor Advertising, Inc. v. Burt, 553 S.W.2d 760, 763 (Tex.1977), involved a contract dispute over a contract that was “solicited, negotiated, and consummated” in Oklahoma.

2005Another case cited by appellants, U-Anchor Advertising, Inc. v. Burt , 553 S.W.2d 760, 763 (Tex. 1977) , involved a contract dispute over a contract that was “solicited, negotiated, and consummated” in Oklahoma.

2025While a corporation may be at home in other locations “in an exceptional case,” the general jurisdiction inquiry “calls for an appraisal of a corporation’s activities in their entirety, nationwide and worldwide” because “[a] corporation that operates in many places can scarcely be deemed at home in all of them.” Id. at 139 n.19, 20. “[T]he ties between the litigation itself and the forum state are irrelevant to the question of whether general jurisdiction exists.” Searcy, 496 S.W.3d at 72 . “[G]eneral jurisdiction relies on the defendant itself being tied up—almost entangled in a web—with the

2022Although there is not a precise formulation for the point at which “jurisdictional contacts reach a tipping point,” the general jurisdiction inquiry is “very different from a specific jurisdiction inquiry” and involves a “more demanding minimum contacts analysis,” with a “substantially higher threshold.” PHC-Minden, L.P. v. Kimberly-Clark Corp., 235 S.W.3d 163, 167-68 (Tex. 2007); see also Searcy, 496 S.W.3d at 72 (“Continuous and systematic contacts that fail to rise to” the level of rendering a defendant essentially at home in the forum state, “are insufficient to confer general jurisdiction

2020Searcy, 496 S.W.3d at 71 (quoting Int’l Shoe Co., 326 U.S. at 318 ). “[M]ore recent Supreme Court cases have clarified that the general jurisdiction analysis entails a high bar.” Id. at 72.

2016Searcy, 496 S.W.3d at 71 (quoting International Shoe Co., 326 U.S. at 318 ). “[M]ore recent Supreme Court cases have clarified that the general jurisdiction analysis entails a high bar.” Id. at 72. “[A] court has general jurisdiction over a defendant only if its ‘affiliations with the [s]tate are so continuous and systematic as to render it essentially at home in the forum [s]tate.’” Id. (quoting –5– Daimler AG v. Bauman, 134 S.Ct. 746, 761 (2014), emphasis added in Searcy).

2020See PHC-Minden, 235 S.W.3d at 169 . 2 As an example of an “exceptional case,” the U.S. Supreme Court has twice pointed to Perkins v. Benguet Consolidated Mining Co., 342 U.S. 437 (1952), a case in which a Filipino corporation temporarily moved its operations to Ohio during World War II.

2016Rather, general jurisdiction relies on the defendant itself being tied up—almost entangled in a web—with the forum state.70 Thus, subsidiaries that are totally unrelated to the forum state, 64 Id. 65 Keeton v. Hustler Magazine, Inc., 465 U.S. 770 , 780 n.11 (1984). 66 466 U.S. 408 (1984). 67 Id. at 416 . 68 Id. at 410 . 69 Id. at 418 . 70 See, e.g., International Shoe Co. v. Washington, 326 U.S. 310, 318 (1945). 19 its economy, and its laws, cannot be haled into that state’s courts merely by virtue of their ownership, and their ownership alone.71 And more recent Supreme Court cases have clarif

2025While a corporation may be at home in other locations “in an exceptional case,” the general jurisdiction inquiry “calls for an appraisal of a corporation’s activities in their entirety, nationwide and worldwide” because “[a] corporation that operates in many places can scarcely be deemed at home in all of them.” Id. at 139 n.19, 20. “[T]he ties between the litigation itself and the forum state are irrelevant to the question of whether general jurisdiction exists.” Searcy, 496 S.W.3d at 72 . “[G]eneral jurisdiction relies on the defendant itself being tied up—almost entangled in a web—with the

2020Remand for Development of Additional Jurisdictional Evidence Contreras argues that if we reverse the trial court’s order denying Corporation’s and Services’s special appearances, we should remand this case in the interest of justice to allow her 3 In Equitable Production Co. v. Canales-Treviño, 136 S.W.3d 235, 243 (Tex. App.—San Antonio 2004, pet. denied), we considered evidence showing the defendant “applie[d] for a certificate of authority, qualifie[d] to do business in Texas, and appoint[ed] an agent in Texas for service of process” as part of the general jurisdiction analysis.

2019The United States Supreme Court has explained that “the general jurisdiction inquiry does not focus solely on the magnitude of the defendant’s in-state contacts,” but “[r]ather, the inquiry calls for an appraisal of a corporation’s activities in their entirety” because “[a] corporation that operates in many places can scarcely be deemed at home in all of them.” BNSF Ry., 137 S. Ct. at –11– 1559 (internal citation omitted); accord Bristol-Myers Squibb, 137 S. Ct. at 1780 ; Daimler, 571 U.S. at 139 n.20.

2019This Court has stated “general jurisdiction contacts are not established by showing that foreign business entities (i) paid Texas franchise taxes, (ii) were registered to do business in Texas, and (iii) had registered agents for service of process in Texas.” N. Frac Proppants, 2017 WL 3275896 , at *16 (citing Asshauer v. Glimcher Realty Trust, 228 S.W.3d 922, 933 (Tex. App.—Dallas 2007, no pet.).

2017See Reiff v. Roy, 115 S.W.3d 700 , 705–06 (Tex. App.—Dallas 2003, pet. denied) (concluding that even a somewhat interactive website did not support general jurisdiction).