Jerry Wilkerson v. RSL Funding, L.L.C.

CourtCourt of Appeals of Texas
DecidedAugust 11, 2011
Docket01-10-01001-CV
StatusPublished

This text of Jerry Wilkerson v. RSL Funding, L.L.C. (Jerry Wilkerson v. RSL Funding, L.L.C.) 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
Jerry Wilkerson v. RSL Funding, L.L.C., (Tex. Ct. App. 2011).

Opinion

Opinion issued August 11, 2011.

In The

Court of Appeals

For The

First District of Texas

————————————

NO. 01-10-01001-CV

———————————

Jerry Wilkerson, Appellant

V.

RSL Funding, L.L.C., Appellee

On Appeal from the 125th District Court

Harris County, Texas

Trial Court Case No. 2009-76347

DISSENTING OPINION

          This case of first impression is important to the jurisprudence of Texas.  It addresses the question of whether a non-Texas resident who uses interactive local websites allegedly to defame a Texas resident is subject to the same jurisdictional standards as a non-Texas resident who uses local print media allegedly to defame a resident. 

Appellee, RSL Funding, L.L.C. (“RSL”), a Houston, Texas company, sued appellant Jerry Wilkerson, a non-Texas resident, for defamation, libel, and business disparagement for posting allegedly defamatory comments on local Houston Yahoo! and local Houston Yelp websites.  In this interlocutory appeal, Wilkerson appeals the trial court’s order denying his special appearance.  In dismissing this case for lack of jurisdiction over Wilkerson, the majority converts the requested review of whether the evidence is legally sufficient to enable Wilkerson to avoid the reach of Texas’ long-arm statute into an objection of its own to the competency of RSL’s evidence to establish the jurisdictional fact that Wilkerson used www.local.yahoo.com to publish his commentsa matter not presented to the trial court and not in dispute.  In doing so, the majority not only erroneously raises the competency of the evidence to support the trial court’s implied findings sua sponte on appeal, but also erroneously shifts the burden of proof from Wilkerson, to negate the jurisdiction of the Texas courts over him, to RSL, to prove it.  Finding the jurisdictional evidence incompetent to support the fact that Wilkerson used www.local.yahoo.com, pursuant to its sua sponte review, the majority erroneously goes on expressly to decline to apply the legal test for the determination of jurisdiction over users of interactive websites—which it acknowledges both local.yahoo.com and yelp.com are—on the ground that Wilkerson did not own and operate the websites on which he posted his comments.  By this means, it reaches the erroneous legal conclusion that the case must be dismissed for insufficient evidence of the court’s jurisdiction over Wilkerson and dismisses the case.  The majority thus derails an important case of first impression in a developing area of law in which internet website owners, search engine operators, and users are all in need of the legal guidance expressly sought by the parties here as a matter of law, not fact.

I respectfully dissent.  I would hold that this Court is called upon to review and apply the law governing personal jurisdiction over the users of interactive websites, not to review the evidence as to whether Wilkerson used local Yahoo! or as to whether the site is interactive.  Applying the legal test for determining jurisdiction over the users of interactive websites, I would hold that by using the interactive local Yahoo! website for Houston and the interactive Yelp website for Houston to post allegedly defamatory comments about a local Houston, Texas business, appellant subjected himself to the long-arm jurisdiction of Texas.

Background

          Wilkerson is a California resident.  RSL is a Texas company that specializes in factoring structured settlement payments.  Wilkerson’s daughter, Trisha Marlene Wilkerson (“Trisha”), also a California resident, won the California State Lottery.  Trisha and RSL entered into an agreement by which Trisha assigned a portion of her future lottery payments to RSL in exchange for a lump sum payment from RSL that she intended to use to purchase a home.  Wilkerson apparently aided Trisha in conducting this business with RSL.  As Trisha completed her business transaction with RSL, Wilkerson, who was unhappy with RSL’s interaction with Trisha, posted comments regarding RSL on two different websites specific to Houston, Texas—local.yahoo.com for Houston and yelp.com for Houston.[1]

          On the local Houston Yahoo website, Wilkerson stated, inter alia, that “dealing with all of the lies by Jim Kelly [one of RSL’s Houston employees] and the non returned promised phone calls by Jim and Mr. Sanchez from accounting” had been “by far the worst experience I have had in my 64 years of life”; that “RSL has lied repeatedly to us and misled us and have caused numerous delays in this project that still has yet to be funded”; that “[b]ecause of all the problems with [RSL] and their violating the contract, we are in the process of a law suit against them and if there is anyone else out there who have had similar experiences with [RSL], please join us in a class action law suit”; and, “Try calling any of their offices, N.Y., L.A., Atlanta etc and you will find that there are no offices there, only phone numbers that are transferred to the Houston Office.  Very clever and manipulating of them.  Just goes to show how they really conduct business, smoke and mirrors.”

In his second Houston local.yahoo.com comment, Wilkerson stated, “Received our check today and now we are able to find out why RSL was so arrogant and mean and delaying everything.  They did not have the money.  The check is no good NSF, non sufficient funds.  Guess their word is as good as their check.”  The local Houston Yahoo! page on which Wilkerson made his comments contained a map and photograph of RSL’s Houston office.

On Yelp’s Houston website, Wilkerson wrote, “Received the check today from RSL and guess what, it appears their word is as good as their check[.]  NSF NON SUFFICIENT FUNDS. 

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Revell v. Lidov
317 F.3d 467 (Fifth Circuit, 2002)
Keeton v. Hustler Magazine, Inc.
465 U.S. 770 (Supreme Court, 1984)
Calder v. Jones
465 U.S. 783 (Supreme Court, 1984)
Moki Mac River Expeditions v. Drugg
221 S.W.3d 569 (Texas Supreme Court, 2007)
BMC Software Belgium, NV v. Marchand
83 S.W.3d 789 (Texas Supreme Court, 2002)
Tabor, Chhabra & Gibbs, P.A. v. Medical Legal Evaluations, Inc.
237 S.W.3d 762 (Court of Appeals of Texas, 2007)
Tempest Broadcasting Corp. v. Imlay
150 S.W.3d 861 (Court of Appeals of Texas, 2004)
Karstetter v. Voss
184 S.W.3d 396 (Court of Appeals of Texas, 2006)
Commint Technical Services, Inc. v. Quickel
314 S.W.3d 646 (Court of Appeals of Texas, 2010)
Choice Auto Brokers, Inc. v. Dawson
274 S.W.3d 172 (Court of Appeals of Texas, 2008)
Michel v. Rocket Engineering Corp.
45 S.W.3d 658 (Court of Appeals of Texas, 2001)
CSR LTD. v. Link
925 S.W.2d 591 (Texas Supreme Court, 1996)
Glattly v. CMS Viron Corp.
177 S.W.3d 438 (Court of Appeals of Texas, 2005)
Touradji v. Beach Capital Partnership, L.P.
316 S.W.3d 15 (Court of Appeals of Texas, 2010)
Paul Gillrie Institute, Inc. v. Universal Computer Consulting, Ltd.
183 S.W.3d 755 (Court of Appeals of Texas, 2006)
Michiana Easy Livin' Country, Inc. v. Holten
168 S.W.3d 777 (Texas Supreme Court, 2005)
Gonzalez v. AAG Las Vegas, L.L.C.
317 S.W.3d 278 (Court of Appeals of Texas, 2009)

Cite This Page — Counsel Stack

Bluebook (online)
Jerry Wilkerson v. RSL Funding, L.L.C., Counsel Stack Legal Research, https://law.counselstack.com/opinion/jerry-wilkerson-v-rsl-funding-llc-texapp-2011.