Bulkley & Associates, LLC v. Department of Industrial Relations, No. 20-40020 (5th Cir. 2021)
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Bulkley is a Texas company that transports refrigerated goods interstate. After a Bulkley truck driver was injured while delivering goods to a customer in California, the Department of Industrial Relations cited Bulkley and assessed penalties for three violations of California health and safety law. Bulkley pursued administrative appeals in California, disputing the Department's authority to require Bulkley to comply with California law. Bulkley lost and has since filed two lawsuits challenging the Department's authority.
The Fifth Circuit addressed personal jurisdiction before subject matter jurisdiction because: (1) Bulkley contests subject-matter jurisdiction without analyzing it, (2) the district court expressed reservations regarding subject matter jurisdiction in Bulkley I without explaining them, and (3) the court's precedents squarely address the personal jurisdiction question in this case. The court concluded that the Department's action of sending a letter to Bulkley in Texas, regarding penalties and inspections related to violations of California law, did not create minimum contacts that establish personal jurisdiction in Texas courts. Therefore, the Department lacks minimum contacts establishing personal jurisdiction in Texas. The court declined to reach the Department's alternative argument that the Texas long-arm statute does not apply to out-of-state officials. Accordingly, the court affirmed the district court's judgment.
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