Gulf Coast International, L.L.C. v. the Research Corporation of the University of Hawaii
01-15-00625-CV
| Tex. App. | Nov 5, 2015Background
- Plaintiff Gulf Coast International (GCI), a Louisiana LLC, sued The Research Corporation of the University of Hawaiʻi (RCUH) alleging breach of contracts and open-account claims for upgrades performed on the research vessel R/V Ka`imikai‑O‑Kanaloa (KOK).
- RCUH is an agency of the State of Hawaiʻi, headquartered in Honolulu; it issued a September 11, 2012 purchase order to GCI for work on the KOK and signed an interim payment/proposal agreement in November 2013 while the vessel was dry‑docked in Oregon.
- RCUH supplied evidence that it has no offices, registered agent, bank accounts, or property in Texas; the KOK has not called at Texas ports during the relevant period.
- GCI admits all installation and on‑vessel work occurred outside Texas (locations include Costa Rica, Panama, Oregon, and Hawaiʻi); invoices and payments were directed to GCI’s Louisiana address.
- GCI emphasized a purported long‑running relationship and GCI personnel/assembly work in Houston; RCUH argued these contacts (emails, calls, parts ordered through third parties, occasional vendor interactions) are unilateral or insufficient to establish Texas jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Texas courts have specific personal jurisdiction over RCUH | GCI: RCUH purposefully availed itself of Texas via repeated contacts with GCI’s Houston office, communications, parts sourcing/assembly in Texas, and long‑term relationship tied to Houston personnel | RCUH: Contracts were issued from Hawaiʻi, all on‑vessel performance and deliveries occurred outside Texas, communications/payments were to Louisiana — these contacts are unilateral or incidental and do not arise from RCUH conduct in Texas | Trial court granted special appearance; appellate summary affirms that specific jurisdiction was not established |
| Whether Texas courts have general jurisdiction over RCUH | GCI: RCUH’s repeated use of Texas vendors and ongoing relationship render it subject to general jurisdiction in Texas | RCUH: Contacts with Texas are neither continuous nor systematic; no offices, agents, property or systemic business in Texas; vendor purchases alone do not support general jurisdiction | General jurisdiction not established; RCUH not "at home" in Texas |
| Whether any asserted contacts were sufficient to show purposeful availment | GCI: Knowledge of Houston operations and work by GCI personnel in Texas show purposeful targeting of Texas | RCUH: Telephone calls, emails, payments to Texas vendors, or GCI’s unilateral decision to perform preparatory work in Texas do not constitute purposeful availment | Court treated such communications and unilateral performance as insufficient for minimum contacts |
| Whether exercising jurisdiction would comport with fair play and substantial justice | GCI: Texas forum convenient for plaintiff (argued implicitly) | RCUH: Litigating in Texas imposes substantial burden on a Hawaiʻi sovereign entity; Hawaiʻi has stronger interest; fairness factors favor defendant | Exercise of jurisdiction would offend fair play and substantial justice; due process bars jurisdiction |
Key Cases Cited
- International Shoe Co. v. Washington, 326 U.S. 310 (established minimum contacts standard for due process) (foundational personal‑jurisdiction doctrine)
- Burger King Corp. v. Rudzewicz, 471 U.S. 462 (forum contacts must be purposeful; long‑term, structured relationships can support jurisdiction)
- Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408 (mere purchases, training trips, and communications insufficient for general jurisdiction)
- Daimler AG v. Bauman, 134 S. Ct. 746 (general jurisdiction limited to forums where corporation is essentially at home)
- American Type Culture Collection v. Coleman, 83 S.W.3d 801 (Tex. 2002) (Texas standard: plaintiff must plead, defendant must negate all bases for jurisdiction)
- BMC Software Belgium, N.V. v. Marchand, 83 S.W.3d 789 (specific review standard for special appearances)
- Parex Res., Inc. v. ERG Res., LLC, 427 S.W.3d 407 (Tex. App.—Houston [14th Dist.] 2014) (contacts like sporadic trips, purchases, and communications insufficient for general jurisdiction)