An Inconvenient Texas

In Grynberg v. Grynberg, the Fifth Court affirmed a forum non conveniens dismissal when the only meaningful connection between Texas and the dispute was the incorporation of the relevant business in Texas: “Although this case involves a single connection to Texas through the incorporation of Pricaspian, it is a controversy involving an entity that maintains its offices in Colorado and individuals who, other than [one], reside in Colorado.” The Court also rejected an argument that the “internal affairs doctrine” created a jurisdictional impediment to a Colorado court proceeding with claims about the governance of the Texas business, finding that the doctrine was a choice-of-law concept rather than a jurisdictional limit. No. 05-16-00636-CV (Nov. 28, 2017) (mem. op.) (The “Pricaspian,” incidentally, is a large salt basin northwest of the Caspian Sea.)

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