Unreported / Non-Citable
Background
FleetPride, a national distributor and service provider of truck parts, sued Harland and Casey McClaskey, Patrick Hudelson, Brandon Jackson, and Jackson Truck Parts & Heavy Equipment LLC. FleetPride alleged that after it purchased the McClaskeys’ business under a 2022 asset-purchase agreement, the defendants operated a competing company, diverted customers, and misused assets and information that FleetPride had acquired.
A Texas state court entered a temporary restraining order broadly restricting the defendants’ competitive conduct and interference with FleetPride’s business, employees, and confidential information. It also authorized expedited discovery. After the case was removed, the federal court initially extended the TRO through October 2, 2026. The McClaskeys and Hudelson later consented to a further extension, while Jackson and Jackson Truck Parts challenged personal jurisdiction and sought dissolution of both state-court orders. FleetPride separately requested jurisdictional discovery concerning the Jackson defendants.
The Court’s Holding
The court extended the TRO against Harland McClaskey, Casey McClaskey, and Patrick Hudelson through October 23, 2026, at 11:59 p.m. Central Time because those defendants consented to the extension. The state court’s expedited-discovery order also remained fully effective as to FleetPride and those three defendants because no party had asked the court to modify or dissolve it as to them.
The court dissolved both the TRO and the expedited-discovery order as to Brandon Jackson and Jackson Truck Parts. Because no specific determination of personal jurisdiction over those defendants had been made and a court must possess jurisdiction to maintain or enforce injunctive relief, the court declined to continue enforcing the orders against them while their jurisdictional challenge remained pending.
The court also denied FleetPride’s request for jurisdictional discovery. For purposes of that motion only, it found that FleetPride had not presented sufficiently particularized facts establishing the possible existence of contacts supporting jurisdiction. Jackson’s sworn declaration denied Texas contacts, and FleetPride’s allegations did not provide the factual showing necessary to justify expedited discovery.
Key Takeaways
- After removal, state-court injunctions and discovery orders remain effective under 28 U.S.C. § 1450 until the federal court modifies or dissolves them.
- The court dissolved interim relief against defendants who challenged personal jurisdiction where no specific jurisdictional determination had been made.
- A plaintiff seeking jurisdictional discovery must identify particularized facts indicating that discovery could uncover a basis for jurisdiction; speculation does not overcome a defendant’s sworn declaration.
Why It Matters
The ruling illustrates that removal does not automatically erase state-court interim orders, but it places those orders under the federal court’s control. Parties challenging personal jurisdiction may obtain relief from an existing state-court TRO before the court resolves the underlying dismissal motion.
It also underscores the evidentiary burden for obtaining jurisdictional discovery. A plaintiff must do more than rely on disputed allegations or characterize merits discovery as jurisdictional; it must identify concrete facts suggesting that targeted discovery could establish the defendant’s forum contacts.