Long Arm of the Law, Kansas Edition

Kelly Hawkins obtained a default judgment in his home state of Kansas against Texas attorney Lloyd Ward and his firms. Hawkins then brought suit in Dallas to enforce the Kansas judgment. Ward contended that the Kansas judgment was ineffective because that state lacked personal jurisdiction over him. The Court of Appeals disagreed. The Kansas court had found jurisdiction based in part on the allegation that the defendants had operated as a joint venture in entering into their representation of Hawkins, and Ward failed to negate that conclusion by clear and convincing evidence. Ward also failed to negate Hawkins’ allegations of the defendants’ contacts with Hawkins in Kansas during the course of the representation. The Court of Appeals therefore affirmed the trial court’s denial of Ward’s motion to vacate the Kansas judgment.

Ward v. Hawkins, No. 05-12-00712-CV