Synergy Global Outsourcing v. Hinduja Global Solutions

2024 Tex. Bus. 2
CourtTexas Business Court
DecidedOctober 31, 2024
Docket24-BC01B-0007
StatusPublished
Cited by5 cases

This text of 2024 Tex. Bus. 2 (Synergy Global Outsourcing v. Hinduja Global Solutions) is published on Counsel Stack Legal Research, covering Texas Business Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Synergy Global Outsourcing v. Hinduja Global Solutions, 2024 Tex. Bus. 2 (Tex. Super. Ct. 2024).

Opinion

E-filed in the Office of the Clerk for the Business Court of Texas 10/31/2024 11:51 AM Accepted by: Beverly Crumley Case Number: 24-BC01B-0007

The Business Court of Texas, 1st Division

SYNERGY GLOBAL § OUTSOURCING, LLC, Plaintiff § v. § Cause No. 24-BC01B-0007 § HINDUJA GLOBAL SOLUTIONS, § INC. and HGS HEALTHCARE, LLC, § Defendants § ═══════════════════════════════════════ OPINION AND ORDER ═══════════════════════════════════════

Before the court is defendants’ motion to remand this case.1 The court

grants that motion because plaintiff filed this suit on December 30, 2019, but

this court does not have authority over cases filed before September 1, 2024.

Act of May 25, 2023, 88th Leg., R.S., ch. 380, §§ 8, 2023 Tex. Sess. Law Serv.

919, 929 (H.B. 19).

1 Although defendants’ October 15, 2024, filing is captioned, “HSG Parties’ Response to the Court’s October 2, 2024[ Order,” their conclusion and prayer asks the court to find that the case is not removable and remand it to the district court. Because that response is in substance a motion to remand, the court treats it as such. Verburgt v. Dorner, 959 S.W.2d 615, 617 (Tex. 1997) (treat pleading’s substance over form). Background

On December 30, 2019, Synergy Global Outsourcing, LLC sued Hinduja

Global Solutions, Inc. (HGSI) in the 191st District Court of Dallas County,

Texas. Synergy later sued Ali Ganjaei and HGS Healthcare, LLC. All parties

were joined before September 1, 2024. This dispute centers on a business

development contract dispute. The district court’s docket sheet shows

seventy-six pages of district and appellate court activity from December 30,

2019, until August 31, 2024. 2

Plaintiff removed the case to this court on October 1, 2024. Its removal

appendix filed two days later contains twenty-five volumes.

On October 3rd, this court requested briefs regarding what effect H.B.

19, § 8 has on this court’s authority to hear this case. H.B. 19, § 1’s operative

sections are codified as Government Code §§ 25A.001-25A.020. GOV’T CODE

§§ 25A.001-25A.020.

Twelve days later, defendants moved for remand arguing based on

statutory plain text that the removal procedures applicable to business court

cases do not apply here because chapter 25A is restricted to actions

2 The district court granted Ganjaei’s special appearance, and the court of appeals affirmed.

-2- commenced on or after September 1, 2024, thus precluding application to this

2019 case. They also cited two non-party memoranda on the judicial branch’s

website stating that only actions filed after September 1, 2024, are removable.

Finally, they referred to prior instances where the legislature limited statutory

amendments to only cases filed after the statute’s effective date.

Plaintiff responded with these basic arguments:

First, a plain language reading of H.B. 19, § 8 reveals no prohibition to the removal of cases, only an affirmation of this Court’s ability to start adjudicating cases filed on or after September 1, 2024.

Second, in instances where the Legislature seeks to prevent the application of a Statute to actions commenced before the effective date, it has utilized specific language that does not appear in H.B. 19, § 8.

Third, H.B. 19 (including § 8) is a procedural not substantive statute; accordingly, the removal process outlined therein applies to ongoing, pre-September 1, 2024 [sic] cases.

Plaintiff expanded those arguments and urged textual points and

referenced nine examples of the legislature including specific language

limiting a statute’s application to cases filed after the statute’s effective date

as evidence that § 8, which omits such explicit language, does not prevent

removal in this case. According to plaintiff, § 8’s purpose is to signal when

the court is open and ready to adjudicate cases as opposed to § 9’s September

-3- 1, 2023, date for when the court can begin the administrative process of

preparing to open for business in 2024.

The court gave the parties an opportunity to respond, which they did.

Defendants reiterated their plain text arguments and addressed

plaintiff’s argument that § 8 exists to signal when the court may begin

accepting cases by arguing it is H.B. 19, §5’s statement that the court was

created September 1, 2023, that says when the court may begin accepting

cases and so, § 8 must mean something different.

Defendants also invoked the Negative Implication Canon (inclusio unius

est exclusio alterius) to argue that H.B. 19’s application to cases filed on or

after September 1, 2024, means that the statute including its removal

provisions do not apply to earlier filed cases.

Finally, defendants addressed plaintiff’s examples of statutes expressly

limiting their application to post-effective date cases by referring to two

examples where the legislature included language stating that the legislative

changes apply to existing cases as negating plaintiff’s argument about needing

express language to limit a change in law to new cases.

Plaintiff’s response reiterated that § 8’s plain text omitted words needed

to give it the meaning defendants argued for and identified four cases

-4- defendants cited that, according to plaintiff, support its premise that § 8

needed to include limiting language to limit the court’s authority to cases filed

on or after September 1, 2024.

Finally, plaintiff urged the court to reject extrinsic materials regarding

legislative intent and defendants’ policy argument that limiting the court’s

authority to newly-filed cases makes good sense.

Neither side contends that there are disputed fact issues, and the court

does not find any. Nor do the parties contend that H.B. 19 is ambiguous on

this issue, and the court does not discern any such ambiguity. Finally, no party

requested oral argument.

Analysis

A. Overview

The issue is whether H.B. 19, § 8 restricts the court’s authority to act to

cases commenced on or after September 1, 2024, as defendants contend, or

whether § 8 marks the date when the court can begin accepting cases, as

plaintiff contends. For the following reasons, the court concludes that § 8

serves both purposes. Thus, the court lacks authority to hear this 2019 case.

-5- B. Applicable Law

This is a statutory construction issue, which is a legal question. In re

Panchakarla, 602 S.W.3d 536, 540 (Tex. 2020) (orig. proceeding). The

applicable principles are:

When a statute’s language is unambiguous, “we adopt the interpretation supported by its plain language unless such an interpretation would lead to absurd results.” “We presume the Legislature included each word in the statute for a purpose and that words not included were purposefully omitted.” We construe statutes and related provisions as a whole, not in isolation, . . ., and as a general proposition, we are hesitant to conclude that a trial court’s jurisdiction is curtailed absent manifestation of legislative intent to that effect, . . ..

Id. (citations omitted).

On June 9, 2023, Governor Abbott signed H.B. 19. H.B. 19, § 1 states:

SECTION 1. Subtitle A, Title 2, Government Code, is amended by adding Chapter 25A to read as follows: . . ..

H.B. 19, § 1. Thereafter, H.B. 19, § 1 adds twenty sections regarding the

business court’s operation, including §§ 25A.004 and 25A.006 concerning

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

Related

Yadav v. Agrawal
2025 Tex. Bus. 7 (Texas Business Court, 2025)
Bestway Oilfield v. Cox
2025 Tex. Bus. 2 (Texas Business Court, 2025)
Lone Star NGL Product Services v. EagleClaw Midstream Ventures
2024 Tex. Bus. 8 (Texas Business Court, 2024)
XTO Energy Inc. v. Houston Pipe Line Company
2024 Tex. Bus. 6 (Texas Business Court, 2024)
TEMA Oil and Gas Company v. ETC Field Services
2024 Tex. Bus. 3 (Texas Business Court, 2024)

Cite This Page — Counsel Stack

Bluebook (online)
2024 Tex. Bus. 2, Counsel Stack Legal Research, https://law.counselstack.com/opinion/synergy-global-outsourcing-v-hinduja-global-solutions-texbizct-2024.