Unreported / Non-Citable
Background
Charles Trent Underwood died while operating a Hyundai-WIA CNC vertical lathe at Martin Sprocket and Gear, Inc. According to the plaintiffs, a spinning steel sprocket escaped the machine’s chuck and struck its metal door with enough force to open it and throw Underwood several feet. His wife, individually and as administrator of his estate, and his surviving parents asserted negligence, gross-negligence, and breach-of-warranty claims against Adept Machine Tools and other defendants.
Adept, a North Carolina corporation, filed a special appearance challenging personal jurisdiction in Texas. Jurisdictional evidence showed that Adept had agreed with Texas-based Hillary Machinery to modify the machine’s drawtube and mount a chuck for Martin Sprocket, knew the machine was destined for the Texas customer, prepared it for shipment, and arranged its direct shipment to Texas. The trial court denied Adept’s special appearance, and Adept pursued an accelerated appeal.
The Court’s Holding
The Sixth Court of Appeals affirmed, holding that Texas courts could exercise specific personal jurisdiction over Adept. Although Adept lacked offices, employees, property, and bank accounts in Texas, the court concluded that Adept purposefully availed itself of doing business in the state by knowingly accepting paid work to modify a machine for a particular Texas customer and arranging for its shipment there. The fact that Hillary initially contacted Adept did not make Adept’s own conduct random, fortuitous, or attributable solely to a third party.
The required connection between Adept’s Texas-directed conduct and the lawsuit was also present because the plaintiffs alleged that Adept’s modifications contributed to the fatal accident. The court did not decide whether the machine or Adept’s work was actually defective; it decided only the jurisdictional issue. Exercising jurisdiction was consistent with fair play and substantial justice because Adept identified no undue burden, while Texas had an interest in adjudicating a fatal Texas workplace accident involving Texas witnesses and additional Texas defendants.
Key Takeaways
- A single commercial transaction can support specific jurisdiction when the defendant knowingly performs paid work for a particular customer in the forum state.
- A defendant need not maintain a physical presence in Texas when its own conduct is purposefully directed toward the state.
- Specific jurisdiction existed because the alleged injury-producing machine modifications were substantially connected to Adept’s Texas-directed transaction.
Why It Matters
The decision illustrates that an out-of-state company may be required to defend a Texas suit even without continuous operations or a physical footprint in the state. Knowingly modifying equipment for an identified Texas customer, profiting from that work, and facilitating delivery to Texas can establish purposeful availment when the litigation arises from those modifications.
The ruling is procedural, not a determination of liability. The plaintiffs must still prove their allegations concerning the machine, the modifications, causation, and damages in the trial court.