No nexus, no jurisdiction.

August 17, 2025

In Lindberg v. Roskind, the Fifth Court considered – and rejected – the plainitff’s argument that the defendant orchestrated a complex corporate scheme involving Texas-based entities. The Court found no evidence that the defendant himself had any direct contacts with Texas, such as conducting business, maintaining offices, or exercising control over the relevant entities from within the state. The defendant’s uncontroverted declaration established that he was a Florida resident, had not visited Texas in over four years, and had no managerial relationship with the Texas entities during the relevant period.

The Court also distinguished the Texas Supreme Court’s Volkswagen precedent, which found specific jurisdiction based on intentional conduct and a direct distribution system targeting Texas. In that case, there was clear evidence of purposeful conduct directed at Texas, including the use of an established distribution system and direct actions affecting Texas consumers. This record contained no such “nexus” between the plaintiff’s claims and alleged jurisdictional contacts. 05-25-00014-CV, Aug. 11, 2025