Business Court Clarifies Amount-in-Controversy Requirements for Injunctive Relief Under Section 25A.004(e) and Adopts Burden-Shifting Framework for Removal Challenges

In C Ten 31 LLC v. Tarbox, the Business Court held that Section 25A.004(e)'s grant of jurisdiction over actions seeking injunctive or declaratory relief incorporates the amount-in-controversy limits of the underlying subsections—here, Subsection (b)'s $5 million threshold. The Court adopted a burden-shifting framework in which the party moving to remand bears the initial burden of showing the pleaded amount is fraudulent or readily established otherwise, while the party asserting jurisdiction bears the ultimate burden of proof at trial.