relatedness inquiry in Texas

2026In that case, the Court began with the following description of the law: “This so-called relatedness inquiry defines the appropriate ‘nexus between the nonresident defendant, the litigation, and the forum.’” [Luciano, 625 S.W.3d] at 14 (quoting Moki Mac, 221 S.W.3d at 579 ).

2025The relatedness inquiry defines “the appropriate ‘nexus between the nonresident defendant, the litigation, and the forum.’” Luciano v. SprayFoamPolymers.com, LLC, 625 S.W.3d 1 , 14 (Tex. 2021) (quoting Moki Mac, 221 S.W.3d at 579 ). “[T]he exercise of specific jurisdiction is prohibited if ‘the suit’ does not ‘arise out of or relate to the defendant’s contacts with the forum.’” Id. (alterations omitted).

2026“An ‘affiliation’ must exist ‘between the forum and the underlying controversy, principally, [an] activity or an occurrence that takes place in the forum [s]tate and is therefore subject to the [s]tate’s regulation.’” Volkswagen, 669 S.W.3d at 430 (quoting Bristol- Myers Squibb Co. v. Superior Ct. of Cal., 582 U.S. 255, 262 (2017)); Luciano, 625 S.W.3d at 14 (“This so-called relatedness inquiry defines the appropriate nexus between the nonresident defendant, the litigation, and the forum.”) (quotation omitted).

2025The relatedness inquiry defines “the appropriate ‘nexus between the nonresident defendant, the litigation, and the forum.’” Luciano v. SprayFoamPolymers.com, LLC, 625 S.W.3d 1 , 14 (Tex. 2021) (quoting Moki Mac, 221 S.W.3d at 579 ). “[T]he exercise of specific jurisdiction is prohibited if ‘the suit’ does not ‘arise out of or relate to the defendant’s contacts with the forum.’” Id. (alterations omitted).

2025TV Azteca v. Ruiz, 490 S.W.3d 29, 53 (Tex. 2016).

2025TV Azteca v. Ruiz, 490 S.W.3d 29, 53 (Tex. 2016).

2026The Court described Ford’s conclusion that the relatedness requirement is satisfied when a company “serves a market for a product in the forum State and the product malfunctions there.” Id. at 348 (quoting Ford, 592 U.S. at 363 ).

2026The Court described Ford’s conclusion that the relatedness requirement is satisfied when a company “serves a market for a product in the forum State and the product malfunctions there.” Id. at 348 (quoting Ford, 592 U.S. at 363 ).

2025Due to the difference between general jurisdiction and specific jurisdiction, “[i]f a defendant does not have enough contacts to justify the exercise of general jurisdiction, the Due Process Clause prohibits the exercise of jurisdiction over any claim that does not arise out of or result from the defendant’s forum contacts.” Id. (citing Seiferth v. Helicopteros Atuneros, Inc., 472 F.3d 266 , 274–75 (5th Cir. 2006)).

2025Instead, the relatedness inquiry demands only that the suit “arise out of or relate to the defendant’s contacts with the forum.” Ford Motor Co., 592 U.S. at 362 (“[W]e have never framed the specific jurisdiction inquiry as always requiring proof . . . that the plaintiff’s claim came about because of the defendant’s in-state conduct.”). 13 “[S]pecific jurisdiction requires us to analyze jurisdictional contacts on a claim-by-claim basis.” Moncrief Oil, 414 S.W.3d at 150 (citing Kelly, 301 S.W.3d at 660 ).

2024The relatedness requirement requires “‘an affiliation between the forum and the underlying controversy, principally, [an] activity or an occurrence that takes place in the forum State and is therefore subject to the State’s regulation.’” Bristol-Myers, 582 U.S. at 262 (quoting Goodyear, 564 U.S. at 919 ).

2023After Moki Mac, the Supreme Court in Bristol-Myers explained that the “arise out of or relate to” standard suggests there must be “an affiliation between the forum and the underlying controversy, principally, [an] activity or an occurrence that takes place in the forum State and is therefore subject to the State’s regulation.” 137 S. Ct. at 1780 (alteration in original) (citing Goodyear Dunlop Tires Operations, S.A. v. Brown, 564 U.S. 915, 919 [] (2011)).

2008See Michiana, 168 S.W.3d at 790-91 (rejecting concept that personal jurisdiction could turn solely on whether or not a contact with the forum state is tortious, observing that such an approach "confuses the roles of judge and jury by equating the jurisdictional inquiry with the underlying merits.”); see also Moki Mac, 221 S.W.3d at 583 (rejecting "substantive-relevance” approach to the relatedness requirement of specific jurisdiction because "in practice it would require a court to delve into the merits to determine whether a jurisdictional fact is actually a legal cause of the injury.”).

2008See Michiana , 168 S.W.3d at 790-91 (rejecting concept that personal jurisdiction could turn solely on whether or not a contact with the forum state is tortious, observing that such an approach "confuses the roles of judge and jury by equating the jurisdictional inquiry with the underlying merits."); see also Moki Mac , 221 S.W.3d at 583 (rejecting "substantive-relevance" approach to the relatedness requirement of specific jurisdiction because "in practice it would require a court to delve into the merits to determine whether a jurisdictional fact is actually a legal cause of the injury.").

2025Instead, the relatedness inquiry demands only that the suit “arise out of or relate to the defendant’s contacts with the forum.” Ford Motor Co., 592 U.S. at 362 (“[W]e have never framed the specific jurisdiction inquiry as always requiring proof . . . that the plaintiff’s claim came about because of the defendant’s in-state conduct.”). 13 “[S]pecific jurisdiction requires us to analyze jurisdictional contacts on a claim-by-claim basis.” Moncrief Oil, 414 S.W.3d at 150 (citing Kelly, 301 S.W.3d at 660 ).

2025The relatedness inquiry requires that the suit “arise out of or relate to the defendant’s contacts with the forum.” Ford Motor Co., 592 U.S. at 362 . “[S]pecific jurisdiction requires us to 13 analyze jurisdictional contacts on a claim-by-claim basis.” Moncrief Oil, 414 S.W.3d at 150 (citing Kelly v. Gen.

2026“An ‘affiliation’ must exist ‘between the forum and the underlying controversy, principally, [an] activity or an occurrence that takes place in the forum [s]tate and is therefore subject to the [s]tate’s regulation.’” Volkswagen, 669 S.W.3d at 430 (quoting Bristol- Myers Squibb Co. v. Superior Ct. of Cal., 582 U.S. 255, 262 (2017)); Luciano, 625 S.W.3d at 14 (“This so-called relatedness inquiry defines the appropriate nexus between the nonresident defendant, the litigation, and the forum.”) (quotation omitted).

2024The relatedness requirement requires “‘an affiliation between the forum and the underlying controversy, principally, [an] activity or an occurrence that takes place in the forum State and is therefore subject to the State’s regulation.’” Bristol-Myers, 582 U.S. at 262 (quoting Goodyear, 564 U.S. at 919 ).

2026“An ‘affiliation’ must exist ‘between the forum and the underlying controversy, principally, [an] activity or an occurrence that takes place in the forum [s]tate and is therefore subject to the [s]tate’s regulation.’” Volkswagen, 669 S.W.3d at 430 (quoting Bristol- Myers Squibb Co. v. Superior Ct. of Cal., 582 U.S. 255, 262 (2017)); Luciano, 625 S.W.3d at 14 (“This so-called relatedness inquiry defines the appropriate nexus between the nonresident defendant, the litigation, and the forum.”) (quotation omitted).

2025Id. at 362; see Volkswagen, 669 S.W.3d at 431 (determining that “[r]elationships may ‘support jurisdiction without a causal showing’ even when the litigation merely relates to the defendant’s forum contacts.”) (quoting Ford Motor Co., 592 U.S. at 362); Luciano, 625 S.W.3d at 17 (refusing to condition specific jurisdiction on a “strict causal connection,” and instead finding it sufficient that SprayFoam “intended to serve a Texas market for the insulation that the Lucianos allege injured them in this lawsuit.”).

2023This so-called relatedness inquiry defines the appropriate “nexus between the nonresident defendant, the litigation, and the forum.” Moki Mac, 221 S.W.3d at 579 ; see also Walden [v. Fiore], 571 U.S. [277,] 284 [(2014)]; Shaffer v. Heitner, 433 U.S. 186, 213 [] (1977).

2021This so-called relatedness inquiry defines the appropriate “nexus between the nonresident defendant, the litigation, and the forum.” Moki Mac, 221 S.W.3d at 579 ; see also Walden, 571 U.S. at 284 ; Shaffer v. Heitner, 433 U.S. 186, 213 (1977).

2015Panel 2013), Justice Jeff Brown observed that “the real common element” in the weather-damage cases is not that "each one arises out of hurricane-inflicted damages, but that in each case the plaintiffs are alleging the same behavior by the insurer." .But, he said, a “business practices” MDL pretrial court with no other limitation would be "impractical and unworkable”—it might become a perpetual pretrial court, '-’with new cases added from every comer of the state’every time a new storm hits.” See id. at 932 (Jeff Brown, J., concurring). ■ ■ Justice Harvey Brown has suggested that the panel’s r

2014Recently, in In re National Lloyds Insurance Company Hurricane Litigation, 422 S.W.3d 926, 930 (Tex.M.D.L.

2023With respect to the relatedness inquiry, we stated that “[i]t is sufficient that [the defendant] intended to serve a Texas market for the insulation that the [plaintiffs] allege injured them in this lawsuit.” Luciano, 625 S.W.3d at 17 (citing Ford, 141 S. Ct. at 1028 ); see also Searcy v. Parex Res., Inc., 496 S.W.3d 58, 67 (Tex. 2016) (“[S]pecific jurisdiction exists when the plaintiff’s claims arise out of or are related to the defendant’s contact with the forum.” (emphasis added) (internal quotations omitted)); Guardian Royal Exch.

2022But the jurisdictional analysis requires courts to focus on the nonresident’s relationship to the forum, not the unilateral activity of a third party. 48 And even when the 47See Burger King Corp. v. Rudzewicz, 471 U.S. 462, 427 (1985); Retamco Operating, Inc. v. Republic Drilling Co., 278 S.W.3d 333, 338 (Tex. 2009). 48Luciano v. SprayFoamPolymers.com, LLC, 625 S.W.3d 1 , 9 (Tex. 2021). 29 nonresident literally has a flood of contacts with the forum, “the exercise of specific jurisdiction is prohibited if the suit does not arise out of or relate to the defendant’s contacts with the forum.” 49

2022In a sworn motion, the appellants alleged that TBS was not “privy to any of Global’s clients’ purchase orders or delivery information,” an allegation sufficient to shift the burden to Allco to prove Allco was a party to the agreement between TBS and 49Id.at 14 (cleaned up). 50Burger King Corp. v. Rudzewicz, 471 U.S. 462, 478 (1985) (“[A]n individual’s contract with an out-of-state party alone [cannot] automatically establish sufficient minimum contacts in the other party’s home forum[.]”); Luciano, 625 S.W.3d at 14 (noting that a flood of purposeful contacts is insufficient for a court to exer

2022But the jurisdictional analysis requires courts to focus on the nonresident’s relationship to the forum, not the unilateral activity of a third party. 48 And even when the 47See Burger King Corp. v. Rudzewicz, 471 U.S. 462, 427 (1985); Retamco Operating, Inc. v. Republic Drilling Co., 278 S.W.3d 333, 338 (Tex. 2009). 48Luciano v. SprayFoamPolymers.com, LLC, 625 S.W.3d 1 , 9 (Tex. 2021). 29 nonresident literally has a flood of contacts with the forum, “the exercise of specific jurisdiction is prohibited if the suit does not arise out of or relate to the defendant’s contacts with the forum.” 49

2021This so-called relatedness inquiry defines the appropriate “nexus between the nonresident defendant, the litigation, and the forum.” Moki Mac, 221 S.W.3d at 579 ; see also Walden, 571 U.S. at 284 ; Shaffer v. Heitner, 433 U.S. 186, 213 (1977).

2021As Chief Justice Roberts noted in his dissent in Moore, “Keeping the relatedness requirement would be inconsistent with the AAIDD’s current guidance; dropping it would be out of step with the newest version of the DSM.” Moore, 137 S. Ct. at 1055 (Roberts, C.J., dissenting). 73 See Tex. HB 1139, 86th Leg., R.S. (2019).

2017See 175 S.W.3d at 916–18.

2015See Ex parte Flores, 387 S.W.3d 626 , 634–35 (Tex. Crim.

2015See Ex parte Flores, 387 S.W.3d 626, 634-35 (Tex. Crim.

2015Because the habeas court did not engage in the relatedness inquiry, the record does not support its finding that applicant meets the DSM-V’s diagnostic criteria. 11 the person’s functional abilities,” including “those that show strength as well as those that show weakness.” See id. at 27.

2015See In re Alcon Shareholder Litig., 387 S.W.3d at 124 . 19589154v1 5 nature of the allegations asserted against the treating dentists are nearly identical in each case, with the only substantive differences being the names of the plaintiffs and minor children, the names of the treating dentists, and the dates on which the minors were treated.

2015See In re Alcon Shareholder Litig., 387 S.W.3d at 124 . 19589154v1 5 nature of the allegations asserted against the treating dentists are nearly identical in each case, with the only substantive differences being the names of the plaintiffs and minor children, the names of the treating dentists, and the dates on which the minors were treated.

2007See In re Ad Valorem Tax Litigation [. . . 216 S.W.3d at 85 ]." Valero says, "Implicit in the relatedness requirement is the idea that it is more efficient to conduct pretrial proceedings on common issues in one forum." Additionally, Valero asserts discovery propounded by the Districts, especially as to inventory, is repetitive.