To the new lawyer, the beginning of a suit can present a daunting series of issues to confront before the real fun of litigation begins. From the defense perspective, one of the most important pre-answer issues may come when the client says, “We don’t do business in Texas.” This is when the lucky litigator finally can use all that knowledge about special appearances gleaned from the bar review class. What? You don’t remember it all? Luckily, you read this column and know exactly where to start.
This primer on special appearances will not provide an in-depth analysis of the law of general or specific jurisdiction, minimum contacts or the evidentiary issues involved with that analysis. But it will provide the framework to help the novice attorney begin a special-appearance analysis, focusing on the procedural mechanisms that lead to a special appearance.
