Michelin North America, Inc. v. Moises Gallegos, 05-17-00617-CV

Appellant Michelin North America moved for a special appearance challenging the trial court’s specific personal jurisdiction.
The trial court denied Michelin’s special appearance in an order signed November 9, 2016; no appeal was filed from that original order.
Michelin filed a "motion to amend order and for reconsideration," citing post‑order decisions but presenting no new grounds. The trial court signed an amended order denying the special appearance on May 18, 2017.
Michelin filed a notice of appeal on June 6, 2017 (within 20 days of the amended order). Appellees moved to dismiss as untimely, arguing the appeal should have been filed within 20 days of the original November 9 order.
The appellate court considered whether the amended order was independently appealable when the reconsideration motion raised no new grounds and whether the notice of appeal was timely.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Michelin’s appeal from the amended order was timely	Gallegos (plaintiffs/appellees): The notice of appeal was untimely because it should have been filed within 20 days of the original November 9 order.	Michelin (appellant): The amended May 18 order restarted the 20‑day appeal window; appeal filed within 20 days of amended order is timely.	Appeal dismissed as untimely because the amended order was not independently appealable; Michelin should have appealed the original order.
Whether an order denying reconsideration of an appealable interlocutory order is itself immediately appealable when no new grounds are raised	Gallegos: Denial of reconsideration that presents no new grounds is not independently appealable.	Michelin: Amended order denying the same special appearance is appealable and restarts the appeal clock.	The court held that interlocutory‑appeal statutes are narrowly construed; denial of a reconsideration motion that presents no new argument is not independently appealable.

Digges v. Knowledge Alliance, Inc., 176 S.W.3d 463 (Tex. App.—Houston [1st Dist.] 2004) (timeliness of interlocutory appeal and related procedural rules)
Brashear v. Victoria Gardens of McKinney, L.L.C., 302 S.W.3d 542 (Tex. App.—Dallas 2009) (timely filing of notice of appeal is jurisdictional)
City of Houston v. Estate of Jones, 388 S.W.3d 663 (Tex. 2012) (interlocutory‑appeal statutes are narrowly construed; motions to reconsider generally do not create new appealable orders)
Bally Total Fitness Corp. v. Jackson, 53 S.W.3d 352 (Tex. 2001) (explaining risks of successive interlocutory appeals and promoting judicial economy)
Michiana Easy Livin’ Country, Inc. v. Holten, 168 S.W.3d 777 (Tex. 2005) (standards for specific personal jurisdiction in Texas)