Velco Chemicals, Inc. v. Polimeri Europa Americas, Inc. F/K/A Enichem Americas, Inc.

CourtCourt of Appeals of Texas
DecidedSeptember 7, 2004
Docket14-03-00395-CV
StatusPublished

This text of Velco Chemicals, Inc. v. Polimeri Europa Americas, Inc. F/K/A Enichem Americas, Inc. (Velco Chemicals, Inc. v. Polimeri Europa Americas, Inc. F/K/A Enichem Americas, Inc.) 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
Velco Chemicals, Inc. v. Polimeri Europa Americas, Inc. F/K/A Enichem Americas, Inc., (Tex. Ct. App. 2004).

Opinion

Affirmed and Memorandum Opinion filed September 7, 2004

Affirmed and Memorandum Opinion filed September 7, 2004.

In The

Fourteenth Court of Appeals

____________

NO. 14-03-00395-CV

VELCO CHEMICALS, INC., Appellant

V.

POLIMERI EUROPA AMERICAS, INC. F/K/A ENICHEM AMERICAS, INC., Appellee

____________________________________________________________

On Appeal from the 11th District Court

Harris County, Texas

Trial Court Cause No. 01-10878

M E M O R A N D U M   O P I N I O N

Appellant Velco Chemicals, Inc. appeals because the trial court denied its special appearance, which it filed after a federal court remanded the case for lack of complete diversity.  While in federal court, Velco answered and counterclaimed, admitting the jurisdictional allegations of appellee Polimeri Europa Americas, Inc. f/k/a Enichem Americas, Inc.  Velco never objected to the court=s jurisdiction over it.  We hold that Velco=s actions in federal court waived its objection to personal jurisdiction in the Texas state court, and we therefore affirm the trial court=s judgment.


FACTUAL AND PROCEDURAL BACKGROUND

Velco is a Delaware corporation with its principal place of business in New York.  EniChem is a Delaware corporation with its principal place of business in Houston, Texas.  EniChem sued Velco for failing to pay two of three invoices for shipments of a chemical known as Tedimon 31.  Thereafter, Velco removed the case to the United States District Court of the Southern District of Texas, alleging diversity of citizenship.  Shortly after removing the case, Velco answered and counterclaimed in federal court.  Velco neither objected to personal jurisdiction nor moved to dismiss for lack of personal jurisdiction under Federal Rule of Civil Procedure 12(b).  Instead, in its answer, Velco admitted EniChem=s allegations that Velco was subject to personal jurisdiction in Texas. 

Four months later, the federal court, finding that complete diversity was lacking, remanded the case to the trial court.  Velco then filed a special appearance, supported by the affidavit of its chief executive officer.[1]  The trial court overruled the special appearance. 

Once the court had the case before it on the merits, it resolved all issues favorably to EniChem.  Velco then appealed the trial court=s order denying its special appearance.

DISCUSSION AND ANALYSIS

1.         The Standard of Review and Applicable Law


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, 805B06 (Tex. 2002), cert. denied, 537 U.S. 1191 (2003); BMC Software Belg., N.V. v. Marchand, 83 S.W.3d 789, 794 (Tex. 2002).  On appeal, we review de novo the trial court=s order granting or denying a special appearance.  Coleman, 83 S.W.3d at 806; Marchand, 83 S.W.3d at 794.  When no findings of fact are issued, we must presume the trial court resolved all factual disputes in favor of its judgment.  Coleman, 83 S.W.3d at 806; Marchand, 83 S.W.3d at 795.

A nonresident defendant objects to a Texas court=s exercise of jurisdiction over it by filing a special appearance under Rule 120a of the Texas Rules of Civil Procedure.  See Tex. R. Civ. P. 120a(2).  The special appearance must strictly comply with Rule 120a, Shapolsky v. Brewton, 56 S.W.3d 120, 140 (Tex. App.CHouston [14th Dist.] 2001, pet. denied), and must be made and determined on sworn motion before any other plea, pleading, or motion that seeks affirmative relief.  Tex. R. Civ. P. 120a(1), (2).

A defendant may waive its right to object to a court=s exercise of personal jurisdiction over it.  See Burger King Corp. v. Rudzewicz, 471 U.S. 462, 472 n.14 (1985); Shapolsky, 56 S.W.3d at 140.  It does this by making a general appearance before the court.  A party enters a general appearance whenever it invokes the judgment of the court on any question other than the court=s jurisdiction; if a defendant=s act recognizes that an action is properly pending or seeks affirmative relief from the court, then that is a general appearance.  See Dawson‑Austin v. Austin, 968 S.W.2d 319, 322 (Tex. 1998), cert. denied, 525 U.S. 1067 (1999) (noting test for general appearance is whether party requests affirmative relief inconsistent with assertion that the district court lacks jurisdiction); Von Briesen, Purtell & Roper, S.C. v. French, 78 S.W.3d 570, 575 (Tex. App.C

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Burger King Corp. v. Rudzewicz
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Velco Chemicals, Inc. v. Polimeri Europa Americas, Inc. F/K/A Enichem Americas, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/velco-chemicals-inc-v-polimeri-europa-americas-inc-texapp-2004.