Rebecca George v. Adam M. Deardorff and Lana Wirsig, 360 S.W.3d 683

Appellant Rebecca George sued Appellees Deardorff and Wirsig (and Harlan Hall) in Texas for libel, slander, defamation, conspiracy, intentional infliction of emotional distress, interference with business relations, and negligence.
Hall, a Texas resident, allegedly conspired to harm George to aid his daughter’s APHA award; Wirsig was initially a client of George, later dismissed from Hall’s Michigan suit.
In the Michigan suit, Hall sued Griffin-related parties; APHA suspended George as an official judge and from competitions for six months based on complaints tied to statements by Wirsig and Deardorff.
George claimed Wirsig and Deardorff provided defamatory statements to APHA; Hall negotiated with Deardorff about Texas employment as a trainer.
The Texas trial court sustained the defendants’ special appearances, finding no personal jurisdiction over nonresidents Deardorff (Pennsylvania) and Wirsig (Missouri).
George did not plead facts establishing Texas contacts by Deardorff or Wirsig; she relied on statements to APHA and Texas-based actions, which the court found insufficient for jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court properly sustained the special appearances.	George contends Texas jurisdiction over Deardorff and Wirsig existed.	Deardorff and Wirsig proved they were nonresidents; George failed to plead specific Texas contacts.	Yes, the trial court correctly sustained the special appearances.

BMC Software Belgium, N.V. v. Marchand, 83 S.W.3d 789 (Tex. 2002) (long-arm jurisdiction framework and due process considerations)
Moncrief Oil Int’l, Inc. v. OAO Gazprom, 332 S.W.3d 1 (Tex. App.—Fort Worth 2010) (review of jurisdiction with regard to minimum contacts)
Michiana Easy Livin’ Country, Inc. v. Holten, 168 S.W.3d 777 (Tex. 2005) (minimum contacts and long-arm analysis; activity in forum matters)
Kelly v. Gen. Interior Constr., Inc., 301 S.W.3d 653 (Tex. 2010) (distinguishes long-arm sufficiency from due process)
Moki Mac River Expeditions v. Drugg, 221 S.W.3d 569 (Tex. 2007) (purposeful availment and minimum contacts standard)
CSR Ltd. v. Link, 925 S.W.2d 591 (Tex. 1996) (definition of specific vs. general jurisdiction)
The Assurances Generales Banque Nationale v. Dhalla, 282 S.W.3d 688 (Tex. App.—Dallas 2009) (relevance of pleadings and evidence to jurisdiction)
National Industrial Sand Ass’n v. Gibson, 897 S.W.2d 769 (Tex. 1995) (definitive statement on defendant’s individual contacts for jurisdiction)
Wheeler v. Methodist Hosp., 95 S.W.3d 628 (Tex. App.—Houston [1st Dist.] 2002) (jurisdictional analysis versus merits distinction)