Alliance Royalties, LLC v. Boothe, 329 S.W.3d 117

Interpleader action filed by Compass Royalty Management to resolve competing claims to oil and gas royalty interests, with funds deposited in court registry.
Alliance Royalties, LLC (Nevis) and Alliance Royalties, Inc. (Anguilla) are related entities; Crithfield is a party to the proceedings and affiliated with Alliance Inc.
Boothes (Dallas residents) and Vento entities (Nevis) filed cross-claims against Alliance entities alleging fraud and other causes of action.
Alliance LLC moved to quash the court's jurisdiction via a special appearance; trial court denied the special appearance and issued findings of fact and conclusions of law.
Question presented is whether Alliance LLC has minimum contacts with Texas sufficient for the trial court to exercise jurisdiction over it in the interpleader/related disputes.
On appeal, the Texas Court of Appeals reviews the trial court’s de novo legal conclusions on jurisdiction, with factual sufficiency review of the trial court’s findings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did appellees plead and prove basis for Texas jurisdiction?	Appellees pleaded jurisdiction and submitted responsive evidence.	Kelly limits reliance on pleadings; burden never shifted without proper pleading.	Trial court correctly considered pleadings and responsive evidence; issue overruled.
Did Alliance LLC have minimum contacts with Texas supporting specific jurisdiction?	Alliance LLC had purposeful Texas contacts via royalty interests, notes, and Texas-related transactions.	Alliance LLC had no Texas contacts; any links were through affiliates or third parties; no purposeful availment.	Alliance LLC had minimum contacts with Texas; issue overruled.
Does Texas jurisdiction over Alliance LLC comport with fair play and substantial justice?	Texas has significant interests in real-property-based disputes and in resolving interpleaded royalties; burden on out-of-state defendant is outweighed by forum interests.	Forum selection and Anguilla forum provisions show unreasonableness under Burger King standards.	Jurisdiction comports with fair play and substantial justice; issue overruled.

Retamco Operating Inc. v. Republic Drilling Co., 278 S.W.3d 333 (Tex. 2009) (purposeful availment; Texas real-property interests; substantial connection to litigation)
Burger King Corp. v. Rudzewicz, 471 U.S. 462 (1985) (traditional notions of fair play and substantial justice)
Michiana Easy Livin' Country v. Holten, 168 S.W.3d 777 (Tex. 2005) (disregard unilateral forum contacts; purposeful instead of random contacts)
Moki Mac River Expeditions v. Drugg, 221 S.W.3d 569 (Tex. 2007) (minimum contacts; connection between defendant, forum, and litigation)
Guardian Royal Exch. Assurance, Ltd. v. English China Clays, P.L.C., 815 S.W.2d 223 (Tex. 1991) (forum state's interest and burdens in international disputes)
Capital Tech. Info. Servs., Inc. v. Arias & Arias Consultores, 270 S.W.3d 741 (Tex. App.-Dallas 2008) (burden-shifting and standards for jurisdictional review)
Kelly v. General Interior Construction, Inc., 301 S.W.3d 653 (Tex. 2010) (pleadings define scope; burden to negate jurisdiction follows pleadings)
Flanagan v. Royal Body Care, Inc., 232 S.W.3d 369 (Tex. App.-Dallas 2007) (permissible use of pleadings and response to special appearance)
Ennis v. Loiseau, 164 S.W.3d 698 (Tex. App.-Austin 2005) (jurisdictional pleading standards)
PHC-Minden, L.P. v. Kimberly-Clark Corp., 235 S.W.3d 163 (Tex. 2007) (imputation of corporate contacts; veil-piercing considerations)