My Vacation Europe, Inc. v. Connie Sigel

CourtCourt of Appeals of Texas
DecidedJanuary 28, 2015
Docket05-14-00435-CV
StatusPublished

This text of My Vacation Europe, Inc. v. Connie Sigel (My Vacation Europe, Inc. v. Connie Sigel) 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
My Vacation Europe, Inc. v. Connie Sigel, (Tex. Ct. App. 2015).

Opinion

Reversed and Rendered and Opinion Filed January 26, 2015

S In The Court of Appeals Fifth District of Texas at Dallas No. 05-14-00435-CV

MY VACATION EUROPE, INC., Appellant V. CONNIE SIGEL, Appellee

On Appeal from the County Court at Law No. 5 Dallas County, Texas Trial Court Cause No. CC-13-06937-E

MEMORANDUM OPINION Before Justices Francis, Lang-Miers, and Fillmore Opinion by Justice Francis My Vacation Europe, Inc. d/b/a Paris Perfect appeals the trial court’s order denying its

special appearance. In two issues, MVE claims the trial court erred by denying its special

appearance because Connie Sigel did not plead general jurisdiction and, even if she had, neither

specific nor general jurisdiction exists. We reverse the trial court’s judgment and render

judgment dismissing the claims against MVE for want of personal jurisdiction.

In the summer of 2012, Sigel planned a trip to Paris, France. While searching on-line for

accommodations, she found the Paris Perfect website (www.parisperfect.com) which advertised

and marketed various vacation rentals. Sigel completed an online reservation inquiry form and

submitted the requested contact information, including her name, phone number, email address,

and the date she intended to travel to Paris. The following day, a MVE representative emailed Sigel and provided details about the “Margaux apartment” which was available during the time

Sigel intended to travel to Paris. After reading the email, Sigel asked for a draft rental

agreement. On July 17, 2012, a MVE representative emailed Sigel a personal booking code and

a personal reservation page, along with instructions for booking the Margaux apartment online.

Sigel accessed the reservation page and entered into a rental contract for the apartment,

submitting payment in full for a seven-night stay beginning September 6, 2012.

Sigel travelled to Paris in September 2012 and began her stay in the Margaux apartment.

On the afternoon of September 10, while Sigel was away from the apartment, someone used a

key to enter the apartment. That same person also had a separate key to access the safe in the

apartment and stole “the majority of [Sigel’s] possessions.” In the days that followed, Sigel

contacted various employees of MVE who represented they were agents and employees of Paris

Perfect. Sigel forwarded MVE a copy of the French police report that noted a key had been used

to access the apartment and a separate key used to open the safe. When Sigel contacted MVE to

submit her claim for reimbursement, MVE informed her that it was not responsible for her losses

and that a French corporation, Westates SCI d/b/a Paris Perfect, owned the Margaux apartment.

Sigel sued MVE and Westates for breach of contract, negligence, negligent

misrepresentation, fraud, conspiracy, conversion, theft of property, and gross negligence. She

claimed both defendants were liable under theories of joint enterprise, piercing the corporate

veil, and alter ego. MVE and Westates each filed a special appearance and a motion to dismiss

based on a forum selection clause contained in the online rental contract. The trial court denied

MVE’s special appearance but granted a continuance for discovery as to Westates’s special

appearance. The trial court also denied the motions to dismiss. MVE now appeals the denial of

its special appearance.

–2– Whether a court has personal jurisdiction over a defendant is a question of law. Am. Type

Culture Collection, Inc. v. Coleman, 83 S.W.3d 801, 805−06 (Tex. 2002). When resolving this

question of law, a trial court must frequently resolve questions of fact. Id. at 806. On appeal, the

trial court’s decision to grant or deny a special appearance is subject to de novo review, but

appellate courts may be called upon to review the trial court’s resolution of a factual dispute. Id.

When the trial court does not issue findings of fact, reviewing courts should presume that the

trial court resolved all factual disputes in favor of its judgment. Id. Here, the relevant facts are

generally not disputed.

A Texas court may exercise jurisdiction over a nonresident only if the Texas long-arm

statute authorizes the exercise of jurisdiction and the exercise of jurisdiction is consistent with

federal and due process guarantees. BMC Software Belgium, N.V. v. Marchand, 83 S.W.3d 789,

795 (Tex. 2002). The Texas long-arm statute permits Texas courts to exercise jurisdiction over a

nonresident “doing business” in Texas. TEX. CIV. PRAC. & REM. CODE ANN. § 17.042 (West

2008). The definition of “doing business” in Texas includes contracting “by mail or otherwise

with a Texas resident” when either party is to perform the contract in whole or in part in this

state or committing a tort in whole or in part in Texas. Id. § 17.042(2). The long-arm statute’s

broad doing-business language allows the statute to “reach as far as the federal constitutional

requirements of due process will allow.” Guardian Royal Exch. Assurance, Ltd. v. English

China Clays, P.L.C., 815 S.W.2d 223, 226 (Tex. 1991).

Federal due process requirements limit a state’s power to assert personal jurisdiction over

a nonresident defendant. See id. Personal jurisdiction is proper when the nonresident defendant

has established minimum contacts with the forum state, and the exercise of jurisdiction comports

with “traditional notions of fair play and substantial justice.” Int’l Shoe Co. v. Washington, 326

U.S. 310, 316 (1945) (quoting Milliken v. Meyer, 311 U.S. 457, 463 (1940)). Minimum contacts

–3– are sufficient for personal jurisdiction when the nonresident defendant “purposefully avails itself

of the privilege of conducting activities within the forum State, thus invoking the benefits and

protections of its laws.” Hanson v. Denckla, 357 U.S. 235, 253 (1958); Michiana Easy Livin’

Country, Inc. v. Holten, 168 S.W.3d 777, 784 (Tex. 2005). There are three parts to a “purposeful

availment” inquiry. Moki Mac River Expeditions v. Drugg, 221 S.W.3d 569, 575 (Tex. 2007).

First, only the defendant’s contacts with the forum are relevant, not the unilateral activity of

another party or a third person. Id. Second, the contacts relied upon must be purposeful rather

than random, fortuitous, or attenuated. Id. And finally, the “defendant must seek some benefit,

advantage or profit by ‘availing’ itself of the jurisdiction.” Michiana, 168 S.W.3d at 785. The

purpose of the minimum contacts analysis is to protect a defendant from being haled into court

when its relationship with Texas is too attenuated to support jurisdiction. Am. Type Culture, 83

S.W.3d at 806.

A nonresident defendant’s forum-state contacts may give rise to two types of personal

jurisdiction: general and specific. Moki Mac, 221 S.W.3d at 575. A general jurisdiction inquiry

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Milliken v. Meyer
311 U.S. 457 (Supreme Court, 1941)
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