Laykin v. McFall

830 S.W.2d 266, 1992 Tex. App. LEXIS 1038, 1992 WL 85247
CourtCourt of Appeals of Texas
DecidedApril 28, 1992
Docket07-91-0276-CV
StatusPublished
Cited by39 cases

This text of 830 S.W.2d 266 (Laykin v. McFall) 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
Laykin v. McFall, 830 S.W.2d 266, 1992 Tex. App. LEXIS 1038, 1992 WL 85247 (Tex. Ct. App. 1992).

Opinions

BOYD, Justice.

Relator Sol W. Laykin brings this petition seeking writ of mandamus directed to the Honorable John R. McFall, respondent. This proceeding arises from a suit against relator by Jane Livermore seeking recovery for conversion, fraud and deceptive trade practices. Relator, a California resident, filed a special appearance, contesting the Texas court’s jurisdiction over him. Respondent, the trial judge, overruled relator’s special appearance, finding the court did have jurisdiction over him.

Parenthetically, while neither respondent nor the real party at interest, Livermore, contests the right of relator to test respondent’s action by this mandamus proceeding, a proper disposition of this proceeding requires us to determine whether the use of that vehicle is proper in this case. We note there is relevant precedent holding that a writ of mandamus may be sought when a special appearance is overruled. United Mexican States v. Ashley, 556 S.W.2d 784, 785 (Tex.1977); Hutchings v. Biery, 723 S.W.2d 347, 350 (Tex.App.—San Antonio 1987, no writ).1

[268]*268However, the viability of that precedent in the instant case requires us to examine closely the recent seminal decision of our Supreme Court in Walker v. Packer, 827 S.W.2d 833 (1992). In that case, and as relevant here, the Court held that the propriety of a trial court refusal to accede to discovery requests might not be tested by mandamus, but, since the refusal could be tested on appeal, mandamus was not available. In the course of its holding, the Court conducted an extensive review of prior holdings indicating that mandamus was available in such instances. In doing so, it reiterated the long standing rule that mandamus would not lie where there is an adequate remedy by appeal and concluded that “an appellate remedy is not inadequate merely because it may involve more expense or delay than obtaining an extraordinary writ.” Id. at 474, 827 S.W.2d at 842. In reaching that conclusion, the Court specifically disapproved cases which, it observed, had not adequately considered the above rule, and applied a more lenient standard justifying mandamus review whenever an appeal “would arguably involve more cost or delay than mandamus.” Id.

However, in its discussion, the Court noted even in discovery cases there were instances where a party might not have an adequate remedy by appeal. One such instance, it commented, would be “where a discovery order compels the production of patently irrelevant or duplicative documents, such that it clearly constitutes harassment or imposes a burden on the producing party far out of proportion to any benefit that may obtain to the requesting party.” Id. at 475, 827 S.W.2d at 843.

We believe the erroneous overruling of a special appearance is analogous to the above situation described by the Supreme Court. When a nonresident’s special appearance is erroneously overruled, the burden on the nonresident is great; he must go through an entire trial in order to have the action dismissed on appeal. Furthermore, the burden is far out of proportion to any benefit that may obtain to the other party. In fact, there is no benefit to the other party in having to go through the expense and delay of an entire trial when the action will be dismissed on appeal with the result that the trial was an exercise in futility. That being so, the burden is heavy on both parties.

We believe the decisions in United Mexican States and Hutchings in holding that a writ of mandamus may be issued to correct an erroneous overruling of a special appearance constitute viable precedent in this ease. Thus, we hold that relator is entitled to seek mandamus in the instant proceeding.

It is well established that, to be entitled to mandamus, a relator must establish a clear legal right to the issuance of the writ. King v. Payne, 156 Tex. 105, 292 S.W.2d 331, 336 (1956). In this cause, relator requests that the trial judge be directed to set aside his order overruling the special appearance and enter an order granting his special appearance dismissing the underlying suit. Alternatively, relator requests that this court reverse the trial court’s order and dismiss the suit for lack of personal jurisdiction.

The suit against relator arose from a transaction in which Livermore, a Texas resident, telephonically contacted relator, a California resident, and requested that he sell a ring for her. They agreed that the ring would be sent to relator and the proceeds, less a commission for relator, would be sent to Livermore in Texas. If relator was unable to sell the ring, it would be returned to Texas.

Livermore sent the ring to relator in California. However, before relator could find a buyer for the ring, Livermore found one in Texas. Livermore requested that relator return the ring, but he refused to do so and attempted to negotiate a purchase of the ring for himself. In doing so, relator sent two letters to Texas (one to Livermore and one to her attorney) and, Livermore alleged, relator made two phone [269]*269calls to her in Texas. During this time, Livermore repeatedly demanded either return of the ring or payment of the amount she requested.

Prior to the suit, relator had never owned any real or personal property in Texas, never solicited any business in Texas, nor ever visited Texas. While relator has had up to twelve customers from Texas, all of the sales to them occurred in states other than Texas.

In U-Anchor Advertising, Inc. v. Burt, 553 S.W.2d 760, 762 (Tex.1977), cert, denied, 434 U.S. 1063, 98 S.Ct. 1235, 55 L.Ed.2d 763 (1978), the Court held that the Texas long arm statute is limited only by the constitutional limitations of due process. See also Hoppenfeld v. Crook, 498 S.W.2d 52, 56 (Tex.Civ.App.—Austin 1973, writ ref’d n.r.e.). The U-Anchor Court went on to say that such a construction is desirable in that it allows courts to focus on the constitutional limitations of due process rather than engaging in technical and abstruse attempts to define the wording of the long arm statute. See U-Anchor, 553 S.W.2d at 762; Hoppenfeld, 498 S.W.2d at 56. Indeed, in Helicópteros Nacionales v. Hall, 466 U.S. 408, 413, 104 S.Ct. 1868, 1871, 80 L.Ed.2d 404, 410 (1984), which involved a question of the right of Texas to exercise in personam jurisdiction over a nonresident, the Supreme Court noted and accepted the holding of the U-Anchor Court that the Texas long arm statute reaches as far as due process permits, with the comment, “Thus, the only question remaining for the court to decide was whether it was consistent with the Due Process Clause for Texas courts to assert in personam jurisdiction over Heli-col.”

For a Texas court to exercise jurisdiction over a nonresident in a manner consistent with constitutional guarantees of due process, three requirements must be met:

(1) The nonresident defendant or foreign corporation must purposefully do some act or consummate some transaction in Texas.
(2) The cause of action must arise from, or be connected with, such act or transaction.

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

Related

GoSecure v. CrowdStrike
2026 Tex. Bus. 13 (Texas Business Court, 2026)
Wayne Lensing and Lefhander Marketing, Inc. v. David Card and Cleo Lowe
417 S.W.3d 152 (Court of Appeals of Texas, 2013)
Pervasive Software, Inc. v. Lexware GMBH & Co. KG
688 F.3d 214 (Fifth Circuit, 2012)
Buffet Partners, L.P. v. Sheffield Square, L.L.C.
256 S.W.3d 920 (Court of Appeals of Texas, 2008)
Moki Mac River Expeditions v. Drugg
221 S.W.3d 569 (Texas Supreme Court, 2007)
J.A. Riggs Tractor Co. v. Bentley
209 S.W.3d 322 (Court of Appeals of Texas, 2006)
Reata Construction Corp. v. City of Dallas
197 S.W.3d 371 (Texas Supreme Court, 2006)
Michiana Easy Livin' Country, Inc. v. Holten
168 S.W.3d 777 (Texas Supreme Court, 2005)
Zimmerman v. Glacier Guides, Inc.
151 S.W.3d 700 (Court of Appeals of Texas, 2004)
Michiana Easy Livin' Country Inc. v. Holten
127 S.W.3d 89 (Court of Appeals of Texas, 2003)
Dowdy v. Miller
122 S.W.3d 816 (Court of Appeals of Texas, 2003)

Cite This Page — Counsel Stack

Bluebook (online)
830 S.W.2d 266, 1992 Tex. App. LEXIS 1038, 1992 WL 85247, Counsel Stack Legal Research, https://law.counselstack.com/opinion/laykin-v-mcfall-texapp-1992.