Things that do not create personal jurisdiction –

In a dispute about alleged undue influence on a Texas-based testator, in the context of evaluating the totality of the defendants’ contacts with Texas, the Fifth Court identified several Texas contacts that will not ordinarily establish personal jurisdiction:

• Written communications in Texas, and personal visits to Texas, when no evidence “establishes what was said in any particular disputed conversation”;
• Simply being named in estate planning documents in a contingent position, when “none of those contingency appointments ever occurred” so the party “did not accept any benefits or obligations or take any action in any of these capacities”; and
• For alter ego, simply the “[f]ailure to observe corporate formalities” or the owner’s “taking a draw” from the company.

Karaa v. Aramoonie, No. 05-17-00571-CV (March 19, 2018).