Long arm, step by step.

After rejecting the novel, but problematic, argument that a corporation chartered outside Texas could not invoke the Texas longarm statute, the Fifth Court found personal jurisdiction over a Louisiana car dealer that sold retail installment contracts to a Dallas-based financial business. The Court proceeded in three distinct steps, in a framework that helps impose order on recent changes in personal jurisdiction law. First, it evaluated minimum contacts for constitutional due process requirements (considering (1) only the defendant’s contacts with the forum, (2) acts that are “purposeful” rather than fortuitous, and (3) whether the defendant sought some benefit, advantage, or profit by “availing” itself of Texas); second, it examined the “relationship among the defendant, the forum[,] and the litigation” to determine whether specific jurisdiction was appropriate; and third, it reviewed whether fair play and substantial justice was satisfied. Winnsboro Auto Ventures LLC v. Santander Consumer USA, No. 05-17-00895-CV (April 19, 2018).