Vertex Industrial, Inc. v. State Farm Lloyds as Subrogee of Jarom Heaton and Kristy Heaton

CourtCourt of Appeals of Texas
DecidedAugust 20, 2021
Docket03-20-00574-CV
StatusPublished

This text of Vertex Industrial, Inc. v. State Farm Lloyds as Subrogee of Jarom Heaton and Kristy Heaton (Vertex Industrial, Inc. v. State Farm Lloyds as Subrogee of Jarom Heaton and Kristy Heaton) 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
Vertex Industrial, Inc. v. State Farm Lloyds as Subrogee of Jarom Heaton and Kristy Heaton, (Tex. Ct. App. 2021).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN

NO. 03-20-00574-CV

Vertex Industrial, Inc., Appellant

v.

State Farm Lloyds as Subrogee of Jarom Heaton and Kristy Heaton, Appellee

FROM THE COUNTY COURT AT LAW NO. 4 OF WILLIAMSON COUNTY NO. 18-1697-CC4, THE HONORABLE JOHN MCMASTER, JUDGE PRESIDING

MEMORANDUM OPINION

Vertex Industrial Inc., a California corporation, appeals the denial of its special

appearance. See Tex. Civ. Prac. & Rem. Code § 51.014(a)(7). State Farm Lloyds, as subrogee of

Jarom and Kristy Heaton, sued Vertex and others, alleging causes of action arising out of a

reverse-osmosis filtration system installed in the Heatons’ home in Texas. In four issues on appeal,

Vertex argues that the trial court erred by denying its special appearance because, in its view, its

contacts with Texas are insufficient to confer general or specific personal jurisdiction. Because

the trial court did not err by concluding that Vertex has sufficient contacts with Texas to establish

specific jurisdiction and that exercising jurisdiction over it would not be unfair, we affirm.

BACKGROUND

The Heatons bought a reverse-osmosis filtration system from a Texas-based

distributor, and the system was installed under the kitchen sink in their home in Williamson

County. In 2017, the Heatons discovered water damage allegedly caused by a failure of the system or its parts. State Farm was the Heatons’ insurer; paid them for repairs, property damage, cleaning

expenses, and alternative living expenses; and became subrogated to their claims arising out of the

system’s alleged failure. State Farm sued the Texas distributor, two other parties, and Vertex to

recover the roughly $33,600 that it spent reimbursing the Heatons.

In its live petition, State Farm alleged that the defendants designed, manufactured,

or distributed the Heatons’ system, bringing it from Vertex’s California place of business into

Texas. It also alleged that Vertex has contacts with Texas by, for example, doing business and

operating here; placing the Heatons’ system into the stream of commerce, knowing that it would

end up in Texas; and not warning the Heatons of the system’s dangers or defects.

In response to State Farm’s petition, Vertex filed a Special Appearance and Motion

to Dismiss, contending that the trial court could not exercise either general or specific personal

jurisdiction. It attached to the special appearance a declaration by one of its officers, who provided

facts showing why Vertex had insufficient contacts with Texas. State Farm responded to the

special appearance and attached evidence of its own. The trial court held a hearing on the special

appearance but heard only attorney argument and no more evidence. In an order reciting that it

considered the special appearance, “the briefing and exhibits, and the argument of counsel,” the

court denied the special appearance, concluding that “it does maintain personal jurisdiction over

Defendant Vertex in this matter.” Vertex now appeals that order.

APPLICABLE LAW AND STANDARD OF REVIEW

A special appearance allows a nonresident to appear in a Texas court for the limited

purpose of challenging the court’s exercise of personal jurisdiction. See Tex. R. Civ. P. 120a(1).

When personal jurisdiction is challenged, the plaintiff bears the initial burden of pleading

allegations sufficient to confer jurisdiction. See Luciano v. SprayFoamPolymers.com, LLC,

2 625 S.W.3d 1, 8 (Tex. 2021); Old Republic Nat’l Title Ins. Co. v. Bell, 549 S.W.3d 550, 559 (Tex.

2018). If the plaintiff meets this burden, the burden shifts to the defendant to negate all bases

for jurisdiction in the allegations. See Luciano, 625 S.W.3d at 8; Old Republic Nat’l Title Ins.,

549 S.W.3d at 559.

“A defendant can negate jurisdiction either legally or factually.” TV Azteca, S.A.B.

de C.V. v. Trevino Ruiz, 490 S.W.3d 29, 36 n.4 (Tex. 2016). “Legally, the defendant can show

that the plaintiff’s alleged jurisdictional facts, even if true, do not meet the personal jurisdiction

requirements.” Id. “Factually, the defendant can present evidence that negates one or more of

the requirements, controverting the plaintiff’s contrary allegations”—for example, evidence that

the defendant has no contacts with Texas. See id.; Kelly v. General Interior Constr., Inc.,

301 S.W.3d 653, 659 (Tex. 2010). “The plaintiff can then respond with evidence supporting the

allegations.” TV Azteca, 490 S.W.3d at 36 n.4; accord Kelly, 301 S.W.3d at 658–59. Thus, a

ruling on a special appearance often requires the trial court to resolve questions of fact. Luciano,

625 S.W.3d at 8; see also Tex. R. Civ. P. 120a(3) (listing evidence that court should consider when

deciding special appearance).

When, as here, the court does not issue findings of fact for its special-appearance

decision, we presume that all fact disputes were resolved in favor of the decision, and imply all

relevant facts necessary to support the judgment that are supported by the evidence, unless they

are challenged on appeal. See Luciano, 625 S.W.3d at 8; M & F Worldwide Corp. v. Pepsi–Cola

Metro. Bottling Co., 512 S.W.3d 878, 885 (Tex. 2017). If the appellate record includes a reporter’s

record and a clerk’s record, as it does in this case, the trial court’s implied findings are not

conclusive but may be reviewed for legal and factual sufficiency of the evidence. BMC Software

Belg., N.V. v. Marchand, 83 S.W.3d 789, 795 (Tex. 2002). However, the ultimate determination

3 of whether a court has personal jurisdiction over a defendant is a question of law, which we review

de novo. See Luciano, 625 S.W.3d at 8.

Texas’s courts may exercise personal jurisdiction over a nonresident if (1) the

Texas long-arm statute authorizes the exercise of jurisdiction and (2) the exercise is consistent with

federal due-process guarantees. Id. The long-arm statute broadly permits jurisdiction over a

nonresident if it “commits a tort in whole or in part in this state,” Tex. Civ. Prac. & Rem. Code

§ 17.042(2); Luciano, 625 S.W.3d at 8, and allows Texas courts to exercise personal jurisdiction

“as far as the federal constitutional requirements of due process will permit,” BMC Software Belg.,

83 S.W.3d at 795. A state may exercise jurisdiction over a nonresident only if it has “minimum

contacts” with the state and maintaining the suit in that state against the nonresident does not offend

“traditional notions of fair play and substantial justice.” Luciano, 625 S.W.3d at 8 (quoting

International Shoe Co. v. Washington, 326 U.S. 310, 316 (1945)).

A nonresident’s contacts with the state can give rise to either general or specific

jurisdiction. Id. There is general jurisdiction when the nonresident’s affiliations with the state are

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Vertex Industrial, Inc. v. State Farm Lloyds as Subrogee of Jarom Heaton and Kristy Heaton, Counsel Stack Legal Research, https://law.counselstack.com/opinion/vertex-industrial-inc-v-state-farm-lloyds-as-subrogee-of-jarom-heaton-texapp-2021.