Estate of Julia Hope Gerald Hood, 02-16-00036-CV

Decedent Julia Hope Hood (Mississippi resident) left a will directing conversion of her estate to cash; estate included ~15-acre Texas property in Tarrant County. niece Lola Webb (Mississippi) was named executrix.
Webb retained Mississippi attorney David Ringer (and the Ringer Law Firm) to probate the will in Mississippi; Ringer obtained Mississippi chancery court orders authorizing Webb to manage the Texas property and later filed to close the Mississippi probate estate.
Ringer mailed a petition, notice of hearing, and proposed releases to beneficiaries (including Texas resident Billy Hood) at their addresses; the Mississippi court closed the estate conditioned on beneficiaries’ releasing claims against Webb to receive distributions.
Billy (and other beneficiaries) later litigated related claims in Texas probate court against Webb; Billy ultimately signed a release while represented by counsel and the Webb litigation settled.
Appellees then sued Ringer and the Ringer Law Firm in Texas for fraudulent inducement, tortious interference with inheritance, and extortion; Ringer filed a special appearance asserting lack of personal jurisdiction.
Trial court denied the special appearance, finding specific jurisdiction; the court of appeals reversed, holding Ringer’s only Texas contact (mailing to Billy) was fortuitous and insufficient for specific jurisdiction, and dismissed claims for lack of personal jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Texas courts have specific personal jurisdiction over Mississippi lawyer/firm for torts allegedly committed in part in Texas	Ringer mailed a release and cover letter to Texas beneficiary and that communication was a crucial, tortious act directed at Texas that induced reliance there, satisfying §17.042(2) and due process	Ringer’s only contacts with Texas were mailing the correspondence while acting in his capacity as Mississippi counsel in Mississippi probate; contacts were fortuitous and insufficient to constitute purposeful availment	Court held no specific jurisdiction: single mailing was fortuitous, did not satisfy purposeful availment or minimum contacts; reversed denial of special appearance and dismissed for lack of personal jurisdiction

BMC Software Belg., N.V. v. Marchand, 83 S.W.3d 789 (Tex. 2002) (standards of review and burden-shifting on special appearance; factual findings and legal review)
Michiana Easy Livin’ Country, Inc. v. Holten, 168 S.W.3d 777 (Tex. 2005) (rejection of a directed-tort theory where contacts themselves, not the tortious nature, must show purposeful availment)
Guardian Royal Exchange Assurance, Ltd. v. English China Clays, 815 S.W.2d 223 (Tex. 1991) (Texas long-arm statute coextensive with federal due process)
Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408 (U.S. 1984) (general jurisdiction requires continuous and systematic contacts)
Int’l Shoe Co. v. Washington, 326 U.S. 310 (U.S. 1945) (minimum contacts and fair play/substantial justice framework)
Searcy v. Parax Res., Inc., 496 S.W.3d 58 (Tex. 2016) (contacts that would be the same regardless of forum location support conclusion of lack of purposeful availment)
Moki Mac River Expeditions v. Drugg, 221 S.W.3d 569 (Tex. 2007) (specific vs general jurisdiction and focus on relation between defendant’s contacts, forum, and litigation)
Kelly v. Gen. Interior Constr., Inc., 301 S.W.3d 653 (Tex. 2010) (plaintiff’s pleading burden to allege long-arm grounds; defendant’s burden to negate)
Retamco Operating, Inc. v. Republic Drilling Co., 278 S.W.3d 333 (Tex. 2009) (analysis of minimum contacts and purposeful availment)