ACT Trading F.Z.E. v. Triple Canopy, Inc.

CourtCourt of Appeals of Texas
DecidedJanuary 22, 2015
Docket02-14-00035-CV
StatusPublished

This text of ACT Trading F.Z.E. v. Triple Canopy, Inc. (ACT Trading F.Z.E. v. Triple Canopy, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
ACT Trading F.Z.E. v. Triple Canopy, Inc., (Tex. Ct. App. 2015).

Opinion

COURT OF APPEALS SECOND DISTRICT OF TEXAS FORT WORTH

NO. 02-14-00035-CV

ACT TRADING F.Z.E. APPELLANT

V.

TRIPLE CANOPY, INC. APPELLEE

----------

FROM THE 355TH DISTRICT COURT OF HOOD COUNTY TRIAL COURT NO. C2013135

MEMORANDUM OPINION 1

This is an accelerated interlocutory appeal from the trial court’s denial of

ACT Trading F.Z.E.’s special appearance. ACT brings two issues challenging

the trial court’s findings supporting the exercise of personal jurisdiction over it

under a reverse veil-piercing theory. We affirm.

1 See Tex. R. App. P. 47.4. Background

The underlying suit arises from a transaction between ACT and Triple

Canopy, Inc., through a third party dealer, for the manufacture and delivery of

several armored vehicles. At the time of the transaction, ACT had a principal

office located in Ajman, a United Arab Emirates free zone, and it manufactured

the vehicles for Triple Canopy there. For a time, ACT stored the vehicles in

Ajman; it then shipped them to Turkey and, later, to Iraq. ACT does business in

the Middle East, particularly Iraq, Afghanistan, and North Africa. ACT’s sole

owner and employee is Dennis Mark, a Granbury, Texas resident. Mark is also

the sole owner of other companies operating overseas (sometimes referred to as

the ACT group of companies). Triple Canopy sought to invoke personal

jurisdiction over ACT under a reverse veil-piercing theory, that is, Triple Canopy

alleged that ACT is an alter ego of Mark and that personal jurisdiction over Mark

can be imputed to ACT. 2

Standard of Review and Applicable Law

Whether a trial court has personal jurisdiction over a defendant is a

question of law, which we review de novo. Moki Mac River Expeditions v. Drugg,

221 S.W.3d 569, 574 (Tex. 2007); TravelJungle v. Am. Airlines, Inc., 212 S.W.3d

2 Although Triple Canopy used the term “fusion” in the trial court––with respect to Mark and the ACT group of companies––it was arguing that Mark’s contacts with Texas should be imputed to ACT, which is commonly referred to as reverse veil piercing. See, e.g., Cappuccitti v. Gulf Indus. Prods., Inc., 222 S.W.3d 468, 482 (Tex. App.––Houston [1st Dist.] 2007, no pet.).

2 841, 845 (Tex. App.––Fort Worth 2006, no pet.). The plaintiff bears the initial

burden of pleading sufficient allegations to bring a nonresident defendant within

the provisions of the long-arm statute. Moki Mac, 221 S.W.3d at 574;

TravelJungle, 212 S.W.3d at 845. Once the plaintiff does so, the burden shifts to

the nonresident defendant to negate all alleged jurisdictional bases. Moki Mac,

221 S.W.3d at 574; TravelJungle, 212 S.W.3d at 845. We review all of the

evidence in making this determination. TravelJungle, 212 S.W.3d at 845. We

may review the trial court’s resolution of disputed fact issues for legal and factual

sufficiency under the same standards of review that we apply in reviewing a

jury’s or trial court’s findings of fact at trial. Id.

Analysis

The following trial court finding is primarily at issue in this appeal:

[T]he totality of the evidence demonstrates that Mark, ACT Trading, Armored and the other entities that make or made up the ACT Group of Companies are integrated to achieve a common business purpose and are so indistinct from one another that the entities, including Mark, are fused into one entity and cannot be found to be separate and distinct from one another for jurisdictional purposes. The Court further finds that the corporate fiction should be disregarded to prevent fraud or injustice.

Applicable Law

Under Texas law, a corporation is presumed to be a separate entity from

its officers and shareholders. See Grain Dealers Mut. Ins. Co. v. McKee, 943

S.W.2d 455, 458 (Tex. 1997); Washington DC Party Shuttle, LLC v. IGuide

Tours, 406 S.W.3d 723, 738–39 (Tex. App.––Houston [14th Dist.] 2013, pet.

3 denied) (en banc). As a result, a plaintiff who relies on the existence of an alter-

ego relationship to ascribe one defendant’s contacts with Texas to a distinct

foreign corporation must prove that such a relationship exists. Washington DC

Party Shuttle, 406 S.W.3d at 738–39; Cappuccitti v. Gulf Indus. Prods., Inc., 222

S.W.3d 468, 482 (Tex. App.––Houston [1st Dist.] 2007, no pet.).

When the primary party is an individual owner or shareholder, “[t]he

corporate fiction is disregarded . . . when a corporation is organized and operated

as a mere tool or business conduit” of that individual. Schlueter v. Carey, 112

S.W.3d 164, 169 (Tex. App.—Fort Worth 2003, pet. denied) (quoting Castleberry

v. Branscum, 721 S.W.2d 270, 272 (Tex. 1986)). In other words, “[a]lter ego

applies when there is such unity between a corporation and an individual that the

separateness of the corporation has ceased and holding only the corporation

liable would result in an injustice.” Nichols v. Tseng Hsiang Lin, 282 S.W.3d 743,

747 (Tex. App.—Dallas 2009, no pet.) (quoting Mancorp, Inc. v. Culpepper, 802

S.W.2d 226, 228 (Tex. 1990)).

Triple Canopy argued that ACT, along with Mark’s other companies,

should be considered a single entity for jurisdictional purposes. The doctrine of

jurisdictional veil piercing is similar to the alter ego concept in substantive liability,

though jurisdictional veil piercing sometimes “involve[s] different elements of

proof.” PHC-Minden, L.P. v. Kimberly-Clark Corp., 235 S.W.3d 163, 174 (Tex.

2007). To show jurisdictional veil piercing, a plaintiff must show that the primary

party “exerts such domination and control over” the defendant “that they do not in

4 reality constitute separate and distinct corporate entities but are one and the

same corporation for purposes of jurisdiction.” Id. at 173. A factor that courts

have considered for jurisdictional veil piercing purposes––and that primarily

relied upon by Triple Canopy––is whether the parties have observed corporate

formalities. Id. at 175; see, e.g., Crithfield v. Boothe, 343 S.W.3d 274, 284–85

(Tex. App.––Dallas 2011, no pet.); Cappuccitti, 222 S.W.3d at 481–82.

Jurisdictional Facts

Mark organized ACT in a UAE free zone for convenience and personal tax

advantages. He charged all of his expenses when travelling to ACT’s credit card

for convenience. Additionally, he and his wife had made significant personal

purchases on the card––for food, medical and dental expenses, and marina

fees––although Mark said that they had paid the company back for those

purchases.

Mark testified that ACT advertises on an internationally available website

along with the other ACT group of companies. 3 The website was set up so that

persons in different geographical areas were directed to different telephone

numbers based on their geographical area. 4 However, Mark also testified that

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Related

Moki Mac River Expeditions v. Drugg
221 S.W.3d 569 (Texas Supreme Court, 2007)
PHC-Minden, L.P. v. Kimberly-Clark Corp.
235 S.W.3d 163 (Texas Supreme Court, 2007)
Nichols v. TSENG HSIANG LIN
282 S.W.3d 743 (Court of Appeals of Texas, 2009)
Mancorp, Inc. v. CULPEPPEER
802 S.W.2d 226 (Texas Supreme Court, 1990)
Schlueter v. Carey
112 S.W.3d 164 (Court of Appeals of Texas, 2003)
Grain Dealers Mutual Insurance v. McKee
943 S.W.2d 455 (Texas Supreme Court, 1997)
Cappuccitti v. Gulf Industrial Products, Inc.
222 S.W.3d 468 (Court of Appeals of Texas, 2007)
Castleberry v. Branscum
721 S.W.2d 270 (Texas Supreme Court, 1986)
Waterman Steamship Corp. v. Ruiz
355 S.W.3d 387 (Court of Appeals of Texas, 2011)
CRITHFIELD v. Boothe
343 S.W.3d 274 (Court of Appeals of Texas, 2011)

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