Zinc Nacional, S.A. v. Bouché Trucking, Inc., No. 09-0734 (per curiam) (docket and briefs)

This case turned on a subtle but important distinction in personal jurisdiction.

Here, Zinc is a Mexican manufacturing company that ships paper to New Mexico, Nevada, and Florida for reprocessing. Along the way, these goods were carried by Bouché Trucking, a Texas corporation that had been subcontracted to carry the merchandise.

In transport, one of the trucks rolled over, injuring its driver. He sued his employer, Bouché, who in turn sued Zinc.

The court of appeals looked (in part) to whether Zinc had other customers in Texas when determining whether Texas courts could exercise specific personal jurisdiction over this claim.

The Texas Supreme Court rejected that reliance on contacts that were “unrelated to the accident in this case.”

Although Zinc does have three or four customers for its other products in Texas, and does receive some raw materials from Texas, these facts are unrelated to the accident in this case and are thus irrelevant to the question of specific jurisdiction. However, they may have some bearing on the existence of general jurisdiction, an issue the court of appeals did not consider.