The mere fact that a client has moved to Texas from another state and receives settlement payments in Texas is insufficient to support personal jurisdiction over the out-of-state lawyers who represented her in an out-of-state lawsuit. After a client failed to receive all the annuity payments which she thought she was to receive, she sued the out-of-state lawyers who had represented her in the out-of-state lawsuit. The federal district court in Fort Worth dismissed the claims for lack of personal jurisdiction.

Richard's basic assertion is that the court should exercise specific jurisdiction over Becker and Zoercher based on her being a resident of Texas and receiving annuity payments there. The annuity payments were the result of a settlement agreement reached in a case litigated and settled in Indiana. Richard hired Becker and the Zoercher firm, both citizens of Indiana at the time she hired them, in Indiana to represent her in a lawsuit filed, litigated, and settled in Indiana. The court finds that Richard moving to Texas prior to the case being settled and her receiving payments pursuant to the settlement agreement in Texas are insufficient to show that Becker and the Zoercher firm purposefully availed themselves of the benefits and protections of the laws of Texas. Thus, the court concludes that Becker and Zoercher do not have minimum contacts with Texas and that the court cannot properly exercise personal jurisdiction over them.

Richard v. R & Q Reinsurance Company, No. 4:07-CV-022-A, 2007 WL 1119212 (N.D. Texas April 13, 2007).