In Padilla-Madden v. Sandoval, Sandoval (Texas) and Madden (Alabama) made oral agreement for Madden to share trustee compensation. No. 04-25-00303-CV, 2026 Tex. App. LEXIS 2250 (Tex. App.—San Antonio March 11, 2026, pet. denied). Sandoval facilitated Madden’s appointment as trustee for Gan Shares Trust. Madden traveled to San Antonio for meetings and executed trust agreements. Madden secured stock shares in Texas safe deposit box. Madden earned $1,000,000, and paid Sandoval $500,000. Sandoval sued in Texas claiming breach and seeking $350,000. Madden filed a special appearance motion, objecting to the Texas court’s personal jurisdiction over her. The trial court denied the motion, and Madden filed an appeal.

The central legal issue concerned whether Texas courts could exercise specific personal jurisdiction over Madden, and the analysis focused on whether Madden purposefully availed herself of the privilege of conducting activities in Texas and whether the claims arose from or related to her contacts with Texas. The Texas long-arm statute allows Texas courts to exercise jurisdiction over nonresidents who contract with Texas residents and perform the contract in whole or in part in Texas. The court examined whether Madden had sufficient minimum contacts with Texas such that maintaining the suit would not offend traditional notions of fair play and substantial justice, as required by federal due process standards. The court considered whether Madden’s activities—traveling to Texas for trust meetings, executing documents, securing property in Texas, and making payments under the alleged oral agreement—constituted purposeful availment of Texas law. The court held that Sandoval’s breach of contract claim arose out of or related to Madden’s contacts with Texas, specifically her role and activities as trustee in Texas. The court also held that the exercise of jurisdiction did not run afoul of “traditional notions of fair play and substantial justice.” The trial court’s order denying Madden’s special appearance was affirmed.