J. A. Riggs Tractor Company v. Michael W. (Mike) Bentley

CourtCourt of Appeals of Texas
DecidedDecember 19, 2006
Docket06-06-00046-CV
StatusPublished

This text of J. A. Riggs Tractor Company v. Michael W. (Mike) Bentley (J. A. Riggs Tractor Company v. Michael W. (Mike) Bentley) 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
J. A. Riggs Tractor Company v. Michael W. (Mike) Bentley, (Tex. Ct. App. 2006).

Opinion



In The

Court of Appeals

Sixth Appellate District of Texas at Texarkana



______________________________



No. 06-06-00046-CV



J. A. RIGGS TRACTOR COMPANY, Appellant



V.



MICHAEL W. ("MIKE") BENTLEY, Appellee





On Appeal from the 62nd Judicial District Court

Hopkins County, Texas

Trial Court No. CV36429





Before Morriss, C.J., Ross and Carter, JJ.

Opinion by Justice Carter



O P I N I O N



J. A. Riggs Tractor Company (Riggs) challenges the Texas court's personal jurisdiction in this breach of contract action. This is an accelerated interlocutory appeal. See Tex. Civ. Prac. & Rem. Code Ann. § 51.014 (Vernon Supp. 2006). The underlying case is a contract dispute between Michael W. Bentley, of Sulphur Springs, Texas, and Riggs, a Texarkana, Arkansas, company. Bentley alleges $74,000.00 in damages from Riggs' cancellation of a contract for a generator.

Riggs raises two main issues on appeal: (1) the trial court erred in finding specific personal jurisdiction; and (2) the trial court erred in finding general personal jurisdiction. Riggs does not raise a factual sufficiency argument, but asserts that the facts, as found, do not suffice to confer jurisdiction. We agree that Riggs lacks constitutionally cognizable minimum contacts with Texas to support either specific or general personal jurisdiction and that the trial court erred in denying Riggs' special appearance.

I. STANDARD OF REVIEW

"Whether a court has personal jurisdiction over a defendant is a question of law." BMC Software Belgium, N.V. v. Marchand, 83 S.W.3d 789, 794 (Tex. 2002). On the underlying standard, the "plaintiff bears the initial burden of pleading sufficient allegations to bring a nonresident defendant within the provisions of the long-arm statute." Id. at 793. At that point, a "defendant challenging a Texas court's personal jurisdiction over it must negate all jurisdictional bases." Id.

We conduct a de novo review of the trial court's denial of a special appearance. Am. Type Culture Collection, Inc. v. Coleman, 83 S.W.3d 801, 806 (Tex. 2002). If we must review the facts underlying the legal conclusion, we review those for legal and factual sufficiency. Marchand, 83 S.W.3d at 794. Where the trial court issues findings of fact (as it did here), this Court reviews the trial court's legal conclusions drawn from the facts to determine their correctness. Id.

II. DUE PROCESS AND PERSONAL JURISDICTION

A. The Texas Long-Arm Statute

The Texas long-arm statute allows Texas courts jurisdiction over nonresident defendants doing business in Texas. Tex. Civ. Prac. & Rem. Code Ann. § 17.042 (Vernon 1997). While the long-arm statute does enumerate certain examples of doing business, it does not provide an exclusive list. Tex. Civ. Prac. & Rem. Code Ann. § 17.042 ("In addition to other acts that may constitute doing business, a nonresident does business in this state if . . ." then setting out three acts); see also Marchand, 83 S.W.3d at 795; Schlobohm v. Schapiro, 784 S.W.2d 355, 256-57 (Tex. 1990). The statute is construed as extending Texas courts' jurisdiction over nonresident defendants as far as the federal constitutional requirement of due process permits. Marchand, 83 S.W.3d at 795; Judd, 8 S.W.3d at 441.

Riggs asserts that no contract was formed so as to confer jurisdiction under the section of the long-arm statute that defines contracting to perform in Texas as one method of "doing business." See Tex. Civ. Prac. & Rem. Code Ann. § 17.042(1). The statute also specifies that "other acts" may constitute "doing business." Tex. Civ. Prac. & Rem. Code Ann. § 17.042. As just discussed, the caselaw interprets this statute as extending to the reaches of due process. "[T]he Texas long-arm statute requirements are satisfied if exercising jurisdiction comports with federal due process limitations." Coleman, 83 S.W.3d at 806. Bentley's pleadings alleged that Riggs "does business in Texas." Thus, we do not need to address, as preliminary matters, the underlying questions of whether there was a formal contract entered or if any contract was to be performed in Texas. Instead, these will be some of the factors considered in the due-process analysis, by considering the precedent from the United States Supreme Court and Texas decisions. See Marchand, 83 S.W.3d at 795.

B. Due Process and "Minimum Contacts"

"The Due Process Clause of the Fourteenth Amendment limits the power of a state court to render a valid personal judgment against a nonresident defendant." World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 291 (1980). A Texas court's personal jurisdiction over a nonresident defendant is constitutional when two conditions are met: (1) the defendant has established minimum contacts with Texas, and (2) the exercise of jurisdiction comports with traditional notions of fair play and substantial justice. Marchand, 83 S.W.3d at 795 (citing Int'l Shoe Co. v. Washington, 326 U.S. 310, 316 (1945)). The "touchstone" of the minimum contacts analysis is purposeful availment, i.e., that "the defendant purposefully avails itself of the privilege of conducting activities within the forum State, thus invoking the benefits and protections of its laws." Michiana Easy Livin' Country, Inc. v. Holten, 168 S.W.3d 777, 784 (Tex. 2005) (quoting Hanson v. Denckla, 357 U.S. 235, 253 (1958)).

The purposeful availment analysis has three components. See Holten, 168 S.W.3d at 785. First, the purposeful availment requirement ensures that a nonresident defendant's contacts with the forum state resulting from the unilateral activities of another party or a third person will not be the sole basis of haling that defendant into the jurisdiction. Burger King Corp. v. Rudzewicz, 471 U.S. 462, 475 (1985); Holten, 168 S.W.3d at 785. Thus, we look at only the defendant's contacts with the forum. Holten

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J. A. Riggs Tractor Company v. Michael W. (Mike) Bentley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/j-a-riggs-tractor-company-v-michael-w-mike-bentley-texapp-2006.