Marquis Construction Services, LLC v. Jesus Torres

Summary

The Thirteenth Court of Appeals of Texas held that Hidalgo County was not a proper venue for Jesus Torres’s workers’ compensation retaliation claim against Marquis Construction Services, LLC. The court concluded that the relevant events occurred primarily in Calhoun County and that Brazoria County was a proper venue because Marquis maintained its principal office there. The court reversed the trial court’s judgment and remanded with instructions to transfer the case to Brazoria County.

Holdings

1. Hidalgo County was not a proper venue because the record did not contain probative evidence connecting a substantial part of the essential events underlying Torres's workers' compensation retaliation claim to Hidalgo County.
2. Brazoria County was a proper venue under section 15.002(a)(3) because Marquis's principal office and central decision makers were located there.
3. The trial court erred by denying Marquis's motion to transfer venue.

Questions Presented

1. Whether Hidalgo County was a proper venue under Texas Civil Practice and Remedies Code section 15.002(a)(1) because all or a substantial part of the events or omissions giving rise to Torres's workers' compensation retaliation claim occurred there.
2. Whether Brazoria County was a proper venue under section 15.002(a)(3) because Marquis maintained its principal office there.
3. Whether the trial court erred by denying Marquis's motion to transfer venue.
4. Whether Marquis was entitled to appellate review of its directed-verdict challenges to causation and its discharge defense.

Disposition

reversed_and_remanded