Moki Mac River Expeditions v. Charles Drugg and Betsy Drugg, Individually, and as Representatives of the Estate of Andrew Patrick Drugg

Texas Supreme Court·Decided March 2, 2007·No. 04-0432·Published

Opinion

IN THE SUPREME COURT OF TEXAS

IN THE SUPREME COURT OF TEXAS

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No. 04-0432

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Moki Mac River Expeditions, Petitioner,

v.

Charles Drugg and Betsy Drugg, Individually, and as Representatives of the Estate of Andrew Patrick Drugg, Respondents

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On Petition for Review from the

Court of Appeals for the Fifth District of Texas

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Argued November 17, 2005

Justice Johnson, joined by Justice Medina, dissenting.

Texas’ long-arm jurisdiction over non residents reaches as far as the federal constitution allows. See Guardian Royal Exch. Assurance, Ltd. v. English China Clays, P.L.C., 815 S.W.2d 223, 226 (Tex. 1991). But, just how far the constitution allows has not been a simple question since International Shoe Co. v. Washington, 326 U.S. 310 (1945). See Mark Maloney, Specific Personal Jurisdiction and the “Arise From or Relate To” Requirement . . . What Does It Mean?, 50 Wash. & Lee L. Rev. 1265, 1266-67 (1993). As to a state’s exercising in personam jurisdiction over a non resident, federal due process requires “only that in order to subject a defendant to a judgment in personam, if he be not present within the territory of the forum, he have certain minimum contacts with it such that the maintenance of the suit does not offend ‘traditional notions of fair play and substantial justice.’” International Shoe, 326 U.S. at 316 (quoting Milliken v. Meyer, 311 U.S. 457, 463 (1940)). Specific jurisdiction over a nonresident defendant comports with federal constitutional due process if the defendant’s alleged liability arises from or is related to an activity conducted within the forum state. Helicopteros Nacionales de Colombia v. Hall, 466 U.S. 408, 414 & n.8 (1984). It is “the defendant’s conduct and connection with the forum” that are critical. Michiana Easy Livin’ Country, Inc. v. Holten, 168 S.W.3d 777, 789 (Tex. 2005) (citing Burger King Corp. v. Rudzewicz, 471 U.S. 462, 474 (1985)).

There is nothing wrong with an enterprise arranging its affairs so that it avoids doing business in or engaging in activities directed toward a particular forum and thereby precludes that forum’s exercise of jurisdiction over it. See World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286, 297 (1980). The key inquiry is whether a defendant has so arranged its affairs. If not, then “he should reasonably anticipate being haled into court” in the forum. Id. The Supreme Court has not been overly restrictive in its view of federal due process limits on a forum’s exercise of jurisdiction over nonresidents that purposefully direct activities toward the forum’s residents:

[W]here a defendant who purposefully has directed his activities at forum residents seeks to defeat jurisdiction, he must present a compelling case that the presence of some other considerations would render jurisdiction unreasonable. Most such considerations usually may be accommodated through means short of finding jurisdiction unconstitutional. For example, the potential clash of the forum’s law with the “fundamental substantive social policies” of another State may be accommodated through application of the forum’s choice-of-law rules. Similarly, a defendant claiming substantial inconvenience may seek a change of venue.

Burger King, 471 U.S. at 477.

Moki Mac is a Utah company which has conducted guided tours in the Grand Canyon for many years. In addition to general advertising and maintaining a website for potential clients to access, Moki Mac’s efforts to attract customers include targeting particular persons to whom it sends brochures describing Moki Mac’s rafting and hiking trips. Its targeted audience includes persons who previously inquired about or have taken its trips. At and for several years prior to the time reservations were made for Andy’s trip in 2001, Moki Mac’s targeted audience included Texas residents. As the Court sets out, some of Moki Mac’s efforts which were directed toward Texas residents included regular advertising in Texas, hiring public relations firms to target media groups and tour operators in Texas, soliciting Texas residents through mass and targeted direct-mail campaigns, and utilizing particular customers to become de facto group leaders to plan, organize and promote Moki Mac trips. Moki Mac also has given discounted trip prices to some Texas clients who brought potential customers to Moki Mac’s attention.

Participants on Moki Mac’s guided rafting and hiking trips engage in activities and encounter conditions which Moki Mac recognizes pose risks of injury and death. Its brochures and “Visitors Acknowledgment of Risk” form (the VAR agreement) identify certain risks, warn that enumerated risks and “other unknown or unanticipated risks may cause injury or death,” and state that Moki Mac has taken reasonable steps to provide “appropriate equipment and/or skilled guides so you can enjoy an activity for which you may not be skilled.” One of the specific dangers warned of was falling during a hike with resulting injury or death. Andy Drugg fell during a hike and was killed.

The Druggs received Moki Mac’s brochures from a Texas acquaintance. After reviewing the brochures and corresponding with Moki Mac from Texas, the Druggs decided to allow thirteen-year-old Andy to go on one of the trips. Moki Mac confirmed Andy’s reservation and in accordance with its usual procedures forwarded to the Druggs a VAR agreement which Moki Mac required to be signed before persons could take one of their trips. Betsy and Andy signed the agreement in Texas and returned it to Moki Mac. The agreement set out several risks which could be encountered on a Moki Mac trip and specified the possibility of injury or death:

In consideration of the services of Moki Mac River Expeditions, Inc., their officers, agents, employees, and stockholders, and all other persons or entities associated with those businesses, (hereinafter collectively referred to as “Moki Mac”), I agree as follows: . . .

I agree to assume responsibility for the risks identified . . . . Therefore, I assume full responsibility for myself, includ

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Moki Mac River Expeditions v. Charles Drugg and Betsy Drugg, Individually, and as Representatives of the Estate of Andrew Patrick Drugg, (Tex. 2007).

Moki Mac River Expeditions v. Charles Drugg and Betsy Drugg, Individually, and as Representatives of the Estate of Andrew Patrick Drugg (Moki Mac River Expeditions v. Charles Drugg and Betsy Drugg, Individually, and as Representatives of the Estate of Andrew Patrick Drugg) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Milliken v. Meyer
311 U.S. 457 (Supreme Court, 1941)
International Shoe Co. v. Washington
326 U.S. 310 (Supreme Court, 1945)
World-Wide Volkswagen Corp. v. Woodson
444 U.S. 286 (Supreme Court, 1980)
Helicopteros Nacionales De Colombia, S. A. v. Hall
466 U.S. 408 (Supreme Court, 1984)
Burger King Corp. v. Rudzewicz
471 U.S. 462 (Supreme Court, 1985)
Michiana Easy Livin' Country, Inc. v. Holten
168 S.W.3d 777 (Texas Supreme Court, 2005)