Fiduciary Shield Doctrine Protects Out-of-State Officer from Personal Jurisdiction in Real Estate Joint Venture Dispute

The Business Court granted a California resident's special appearance and dismissed third-party claims without prejudice, holding that respondents failed to plead or prove sufficient Texas contacts to support personal jurisdiction over the officer who allegedly acted solely in his corporate capacity. The court applied the fiduciary shield doctrine despite allegations of fraud and misrepresentation in connection with a failed joint venture to acquire Princeton, Texas real property.