Jurisdiction and wearing many hats — UPDATED

“[W]e decline to extend the Supreme Court’s holding in Burnham to find personal jurisdiction over James in all of his capacities simply because he was served in his individual capacity while present in Texas. Such a holding would conflict with the consistent position taken by Texas courts that actions taken by an individual in a representative capacity are separate and distinct from actions taken in an individual’s personal capacity.” Hanschen v. Hanschen, No. 05-19-01134-CV (May 28, 2020) (mem. op.) A concurrence noted: “We did not conclude whether the trial court could obtain personal jurisdiction over James in his representative capacities in the future if he were to be served properly in those capacities.”