Frank Luciano and Helene Luciano v. SprayFoamPolymers.com, LLC

Summary

The Supreme Court of Texas considers whether Texas courts may exercise specific personal jurisdiction over an out-of-state manufacturer of spray-foam insulation. The Court holds that the manufacturer purposefully availed itself of the Texas market through its use of a Texas distribution center and an in-state sales representative, and that the Lucianos’ claims were sufficiently related to those contacts. The Court reverses the court of appeals’ dismissal for lack of personal jurisdiction.

Holdings

1. SprayFoam purposefully availed itself of the Texas market through its deliberate use of a Texas distribution center and a Texas-based sales representative to distribute and solicit sales of its products.
2. The Lucianos' claims arose out of or related to SprayFoam's Texas contacts because the alleged injuries occurred in Texas to Texas residents and involved the same type of insulation for which SprayFoam served the Texas market.
3. Exercising specific personal jurisdiction over SprayFoam is consistent with traditional notions of fair play and substantial justice.

Questions Presented

1. Whether Texas courts could exercise specific personal jurisdiction over SprayFoam under the Texas long-arm statute and federal due-process requirements.
2. Whether SprayFoam purposefully availed itself of the Texas market through its use of a Texas distribution center and Texas sales representative.
3. Whether the Lucianos' claims arose out of or related to SprayFoam's Texas contacts without proof of a strict causal connection between those contacts and the particular product installed in the Lucianos' home.
4. Whether exercising jurisdiction over SprayFoam would offend traditional notions of fair play and substantial justice.

Disposition

reversed_and_remanded