Negotiation doesn’t create jurisdiction

Liederman, a New York lawyer, sent seventy-seven emails to Texas, made five phone calls there, and signed and delivered three tolling agreements to Davis, a Texas-based attorney, “over a span of three years in working towards settling appellees’ claims.”  The Fifth Court found no specific personal jurisdiction, observing: “Liederman could have ‘quite literally’ interacted with Davis, who could have been anywhere in the world, in the same manner. . . . It is apparent that Invasix’s contacts with Davis were based on her representation of the nonresident plaintiffs in the personal injury lawsuit and had nothing to do with the State of Texas.” Invasix, Inc. v. James, No. 05-19-00494-CV (Feb. 25, 2020) (mem. op.) (emphasis added). The Court also found no general personal jurisdiction, applying recent Texas and United States Supreme Court opinions that have limited the scope of that doctrine.