Texas Business Court Decision – February 3, 2026

No. 25-BC04B-0017 Alamo Title Company v. WFG National Title Company of Texas, LLC (Fourth Division, Judge Sharp)  25-bc04b-0017-alamo-title-company-v-wfg-national-title-company-2026-tex-bus-6.pdf

Jurisdiction. Alamo sued WFG alleging WFG raided its employees and customers and misappropriated sensitive business information; it also accused WFG of tortiously interfering with customer contracts and of aiding and abetting Alamo’s former president and other employees in breaching their fiduciary duties. Alamo sued in Bexar County district court, and WFG removed the action to the Business Court. Alamo now moves to remand.

Held: Jurisdiction is proper in the Business Court because the amount in controversy exceeds $5 million and the suit involved  two of the topics enumerated in Texas Government Code’s  Chapter 25A.  See Tex. Gov’t Code Sec. 25A.004(b) and (d).

(1) Where the petition is silent as to the whether the suit satisfies the amount-in-controversy requirement, the court looks next to the removal notice, and if it satisfies the amount-in-controversy, the burden shifts back to the party advocating remand to establish that the defendants’ amount-in-controversy pleading is fraudulent or that the amount is readily established as $5 million or less; here, WFG’s removal notice pleads the amount exceeds $5 million, and Alamo provided no evidence with its motion to remand rebutting the jurisdictional amount; further, its petition showed that the combination of past  and future damages exceeds the minimum threshold;

(2) There are at least two statutory clauses that confer jurisdiction as Alamo’s suit alleged;(a) that a managerial official, its former president,  breached a duty owed to the organization by reason of his position and status – Sec. 25A.004(b)5) – and (b) the suit relates to  ownership or use  of intellectual property- see Sec. 25A.004(d) (4-5); and

(3) Having determined that Chapter 25A grants jurisdiction based on the clauses specified above, the court also concludes the jurisdictional grant extends to the entire suit- see In re Durant, 720 S.W. 3d 438, 443 (Tex. App. – 15th Dist. 2025, orig. proceeding)