Specific Jurisdiction Established Over Out-of-State Airline Based on Texas Operations Under Multi-State Alliance Agreement
Judge Jerry D. Bullard
Decided February 19, 2026
Mem. Op.
Jurisdiction & Remand
In American Airlines v. JetBlue Airways, the Business Court of Texas denied JetBlue's special appearance challenge, finding that American had pleaded sufficient facts to establish personal jurisdiction over JetBlue in a dispute arising from the Northeast Alliance's profit-sharing agreement. The court held that JetBlue failed to meet its burden to negate all jurisdictional allegations despite arguing its Texas contacts were minimal.
Court Staff Summary
Denying the defendant's special appearance because the Court has specific jurisdiction over the defendant.
Background: The Northeast Alliance Dispute
American Airlines and JetBlue Airways established the Northeast Alliance (NEA) in 2020 to increase services among certain Northeast states and Texas. The alliance's key profit-sharing component was the Mutual Growth Incentive Agreement (MGIA), which governed revenue distribution proportionate to each airline's annual contribution at NEA airports. After the federal government enjoined the NEA's operations but permitted the airlines to complete the prescribed audit process to settle their obligations for flights flown on or before July 18, 2023, American sued JetBlue in the Texas Business Court for breach of contract to recover amounts allegedly due under the MGIA's reconciliation and payment process.
The Jurisdictional Challenge
JetBlue filed a special appearance asserting the court lacks specific jurisdiction. While JetBlue admitted it contracted with Texas-resident American, the airline claimed its contacts with Texas did not satisfy the requirements for personal jurisdiction. The court's memorandum opinion and order, filed February 19, 2026, addressed whether American had pleaded sufficient facts to establish personal jurisdiction and whether JetBlue met its burden to negate all jurisdictional allegations.
The Court's Ruling
The Business Court of Texas denied JetBlue's special appearance. The court found that American had pleaded sufficient facts to establish personal jurisdiction over JetBlue. Critically, the court determined that JetBlue had not met its burden to negate all jurisdictional allegations. The court held a hearing on the special appearance on January 12, 2026, and considered the pleadings, oral and written arguments, relevant evidence, and applicable law before issuing its decision.
Procedural Notes
Both parties filed unopposed motions to seal confidential information during the proceedings. Upon finding good cause under Texas Rule of Civil Procedure 76a, the court issued a sealing order on January 8, 2026. American filed both public and sealed versions of its response in opposition to JetBlue's special appearance on December 8, 2025, and JetBlue filed its reply on December 22, 2025. JetBlue also filed a request for written opinion on January 12, 2026, which resulted in this memorandum opinion and order.