Morris Industries, Inc. v. Trident Steel Corporation

CourtCourt of Appeals of Texas
DecidedDecember 1, 2011
Docket01-11-00380-CV
StatusPublished

This text of Morris Industries, Inc. v. Trident Steel Corporation (Morris Industries, Inc. v. Trident Steel Corporation) 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
Morris Industries, Inc. v. Trident Steel Corporation, (Tex. Ct. App. 2011).

Opinion

Opinion issued December 1, 2011.

In The

Court of Appeals

For The

First District of Texas

————————————

NO. 01-11-00380-CV

———————————

MORRIS INDUSTRiES, INC., Appellant

V.

TRIDENT STEEL CORPORATION, Appellee

On Appeal from the 215th Judicial District Court

Harris County, Texas

Trial Court Case No. 2009-57578

MEMORANDUM OPINION

In this interlocutory appeal, Morris Industries, Inc., appeals the trial court’s order denying its special appearance.1  Trident Steel Corporation sued Morris, a New Jersey corporation, alleging claims for breach of contract and breach of warranty.  Morris filed a special appearance subject to its answer, which the trial court denied.  Morris appeals, contending that it lacks the minimum contacts with Texas required for a Texas court to exercise jurisdiction over it.  Finding no error, we affirm the trial court’s order.

Background

Morris is a New Jersey corporation headquartered in New Jersey. Morris makes and distributes pipes, casings, and other items used in the oil and gas industry.  In February 2008, Trident, a Missouri corporation with offices in Texas, began ordering oilfield couplings from Morris for delivery to its Houston location.

Pursuant to its contract with Trident, Morris shipped couplings to the Port of Houston. Upon their arrival, Morris paid and arranged for the couplings to be offloaded from the ships and trucked to threading facilities designated by Trident.  Morris retained title to the couplings and bore the risk of their loss until this point; possession and title to the couplings transferred to Trident at the threading facilities.  In November 2008, Trident became dissatisfied with Morris’s couplings, asserting that they had failed testing performed by Trident and Trident’s customers.  Trident began rejecting Morris’s deliveries. 

In September 2009, Trident sued Morris in Harris County, alleging claims for breach of contract and breach of warranty.  Morris specially appeared, asserting that it was not subject to personal jurisdiction in Texas. Trident moved for a continuance before the special appearance hearing.  The trial court, without ruling on Trident’s motion for continuance, denied Morris’s special appearance.  Morris then appealed the trial court’s ruling to this Court.  On appeal, we held that Morris had negated Trident’s jurisdictional allegations, but remanded the case to the trial court to consider Trident’s request for jurisdictional discovery, pending at the time the trial court denied Morris’s motion. Morris Indus., Inc. v. Trident Steel Corp., No. 01-09-01094-CV, 2010 WL 4484351, at *5 (Tex. App.—Houston [1st Dist.] Nov. 10, 2010, no pet.) (mem. op).  On remand, Trident adduced additional jurisdictional facts relevant to Morris’s contacts with Texas.   

Morris maintains offices in New Jersey, New York, Pennsylvania, and Connecticut.  Morris has no offices in Texas, no employees in Texas and no agent in Texas for service of process.  Morris sells its products via a toll-free number listed on its website and through Iron Angeles of Colorado, Inc., an independent distributor located in Colorado.


Peter Brebach, a sales agent for Iron Angeles, brokers sales between Morris and its customers.  Brebach conducts research on behalf of Morris, locates Texas buyers interested in purchasing steel couplings, and communicates the results of his research to Morris.  For the contracts at issue in this case, Brebach negotiated purchase orders with Trident on behalf of Morris; Morris paid Brebach a commission for these sales pursuant to a “formal agreement.”  Brebach routinely copied corporate representatives from Morris and Trident on his correspondence.  In some instances, Morris directly communicated to Trident its progress in performing the orders.

Morris purchased couplings from a Chinese foundry and shipped them from China F.O.B. the Port of Houston.  Once the couplings arrived, Morris hired a local trucking company to pick up each order from a shipyard facility and transport the couplings to Trident’s designated “threading” facilities.  Craig Laine, a purchasing agent for Morris, travelled to Houston during the product delivery process to familiarize himself with the threading facilities and to determine how to transport Morris’s couplings to those facilities.  It was Laine who arranged for trucks to deliver Morris’s products from the Port of Houston to the Houston threading facilities.  Morris owned the couplings until their delivery to the threading facilities; Morris therefore bore the risk of loss from the time it shipped the couplings until it transferred possession to Trident at the threading facilities.  After delivering each order, Morris prepared and sent Trident an invoice for expenses. 

After Trident notified Morris of the alleged defects, Morris attempted to cure its imperfect tender.  Morris leased a storage facility in Houston so that Laine and Mike Stern, Morris’s Vice President, could inspect the couplings.  Laine travelled to Houston approximately six times on business related to the contracts between Morris and Trident.  While in Houston, he personally segregated the couplings by heat number.  Once Laine segregated the couplings, he arranged for two Houston companies to test them for defects.  One company tested the couplings on behalf of both Trident and Morris, but the other tested the couplings solely at Morris’s direction. 

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Morris Industries, Inc. v. Trident Steel Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/morris-industries-inc-v-trident-steel-corporation-texapp-2011.