U.S. Supreme Court

Case Status


Docket Number


Cert. Denied

Oral Argument Date

November 14, 2016

Lower Court Opinion


Questions Presented

(1) Can a defendant’s general business contacts or sporadic and involuntary contacts in the forum state that have no causal connection to the plaintiff’s cause of action establish specific personal jurisdiction consistent with the Due Process Clause?

(2) Under the “effects test” described in Calder v. Jones, 465 U.S. 783 (1984), and Walden v. Fiore, 134 S. Ct. 1115 (2014), must the forum state be the “focal point” of the alleged defamatory statements and the injury suffered, or are the defendant’s more general efforts to “serve the market” sufficient to establish specific jurisdiction?

Case Updates

Cert. petition denied

June 26, 2017

U.S. Chamber asks Supreme Court to review Texas decision misapplying personal jurisdiction precedents

November 14, 2016

A coalition of trade associations filed an amicus brief urging the U.S. Supreme Court to grant review of a decision misapplying the Court’s personal jurisdiction precedents. In the decision below, the Texas Supreme Court upheld the exercise of specific personal jurisdiction over defendants based on their contacts with the forum, even though these contacts were completely unrelated to the plaintiff’s claim.

This theory of personal jurisdiction, the amicus brief explained, is directly contrary to the U.S. Supreme Court’s precedents establishing clear lines between general and specific personal jurisdiction. Moreover, upholding specific jurisdiction based on defendants’ contacts unrelated to the plaintiff’s claim effectively nullifies the due process limits on general jurisdiction and transmutes specific jurisdiction into de facto general jurisdiction. Beyond the doctrinal problems with the Texas Supreme Court’s holding, the brief explained that the decision will also have disastrous practical consequences, causing serious harm to American businesses, overburdening the courts, and emboldening states to regulate conduct occurring entirely outside their borders, in violation of principles of federalism.

In addition to the U.S. Chamber, the coalition joining the brief included the American Tort Reform Association, National Federation of Independent Business, and the Texas Association of Business.

Andrew J. Pincus, Archis A. Parasharami, and Matthew A. Waring of Mayer Brown LLP served as counsel for the U.S. Chamber of Commerce on behalf of the U.S. Chamber Litigation Center.

Case Documents