Specific Jurisdiction Requires Claims to Arise From Texas Conduct: Business Court Dismisses Out-of-State Manufacturers in Lien-Priority Dispute

In Daimler Truck Financial Services v. Vanguard National Trailer Corp., Division 8 granted Indiana-based trailer manufacturers' special appearance and dismissed all claims for lack of personal jurisdiction, holding that plaintiff failed to establish its fraud, conversion, and declaratory judgment claims arose from defendants' conduct in Texas. The court found that while plaintiff alleged defendants engaged in a fraudulent MCO scheme that injured a Texas lender, the claims stemmed from defendants' California dealings with California entities, not from purposeful contacts with the forum state.