Summary
The Thirteenth Court of Appeals of Texas issued a memorandum opinion reversing the trial court's denial of Google LLC's special appearance challenging personal jurisdiction in a lawsuit brought by the State of Texas under the Deceptive Trade Practices Act. Analyzing both general and specific jurisdiction standards under Texas long-arm statutes and federal due process requirements, the court concluded that Google's contacts with Texas were insufficient to establish general jurisdiction and that the claims lacked the necessary nexus for specific jurisdiction. Accordingly, the court rendered judgment dismissing all claims for lack of personal jurisdiction.
Topics
Practice areas
Questions Presented
- Whether the trial court erred in finding general jurisdiction over Google in Texas.
- Whether the trial court erred in finding specific jurisdiction over Google in Texas.
Holdings
- The trial court erred; Google is not essentially at home in Texas and therefore general jurisdiction does not exist.
- The trial court erred; specific jurisdiction does not exist because the alleged contacts are not related to the claims and lack purposeful availment.
Key quotations
“General jurisdiction requires that a defendant be “essentially at home” in the forum state.”
“Specific personal jurisdiction focuses on the defendant’s connections with the state and its relationship to the plaintiff’s claims.”
Factual background
Google operates globally with a small number of employees and facilities in Texas, including data centers and office space. The State of Texas sued Google under the Texas Deceptive Trade Practices Act alleging deceptive practices affecting Texas residents.
Procedural history
The trial court denied Google's special appearance, finding personal jurisdiction. Google appealed, arguing lack of both general and specific jurisdiction under Texas law and the Fourteenth Amendment.