Texas Business Court Decision – February 19, 2026

No. 25-BC08-007  American Airlines, Inc. v. JetBlue Airways Corporation (Eighth Division, Judge Bullard) 25-bc08a-0007-american-airlines-v-jetblue-airways-2026-tex-bus-7.pdf

Jurisdiction. In 2020, American and JetBlue formed the Northeast Alliance to increase flight services between the Northeast and Texas;  the Alliance’s key profit-sharing component was the Mutual Growth Incentive Agreement (MGIA) which governed each party’s revenue share. The federal government enjoined the Alliance’s operations, but permitted the airlines to complete an audit to settle  their obligations under the MGIA for flights after July 18, 2023. American sued JetBlue in the Business Court for breach of contract due to amounts owed per the audit. JetBlue filed a Special Appearance contending the Business Court lacked specific jurisdiction. Held: the Special Appearance is denied, as the Business Court had specific jurisdiction.

1.  It is not disputed that JetBlue, a nonresident defendant with no place of business in Texas, is not subject to general personal jurisdiction in Texas.
2. With respect to whether the Business Court had specific jurisdiction, JetBlue purposefully sought benefits from  Texas by operating thousands of flights to and from Texas, by targeting Texans with advertising, and by continuously employing Texas employees at Texas airports working from Texas property leased by JetBlue;
3. A forum-selection clause in the MGIA establishing New York federal court as the choice of forum and New York law as the choice of law is not dispositive, as those clauses must be balanced with JetBlue’s other Texas contacts, and the evidence now before the Business Court establishes that Texas contacts outweigh enforcing the choice of forum and choice of law clauses;
4. JetBlue’s alleged liability arises out of or is related to its activity in Texas, and American expressly pleaded the substantial connection between JetBlue and this litigation, citing the contacts listed in Point 2, above; further, the suit seeks to recover revenue derived in part from JetBlue’s increased activity and presence in Texas;
5. Given JetBlue’s contacts with Texas, the assertion of jurisdiction over JetBlue comports with traditional notions of fair play and substantial justice; JetBlue had failed to present a compelling case that assertion of jurisdiction would be unreasonable; the possibility that American could obtain relief in another forum is irrelevant because of Texas’s strong interest in adjudicating this dispute.