Wendy Padilla-Madden v. Cristian Sandoval

Summary

The Fourth Court of Appeals of Texas affirmed the denial of Wendy Padilla-Madden’s special appearance in Cristian Sandoval’s breach-of-oral-agreement suit. The court held that Madden purposefully availed herself of Texas through her activities as trustee and that Sandoval’s claim related to those contacts, supporting the exercise of specific personal jurisdiction.

Holdings

1. Madden purposefully availed herself of the privilege of conducting activities in Texas through her contacts as trustee, including attending meetings, executing the Gan Shares Trust Agreement, and taking possession of trust-related stock in Texas.
2. Sandoval's breach-of-contract claim arose from or related to Madden's Texas contacts, satisfying the relatedness requirement for specific personal jurisdiction.
3. Exercising specific personal jurisdiction over Madden in Texas would not offend traditional notions of fair play and substantial justice.

Questions Presented

1. Whether the trial court erred in denying Madden's special appearance because she did not purposefully avail herself of the privilege of conducting activities in Texas.
2. Whether Sandoval's breach-of-contract claim arose from or related to Madden's contacts with Texas for purposes of specific personal jurisdiction.
3. Whether exercising specific personal jurisdiction over Madden comported with fair play and substantial justice.

Disposition

affirmed