CROSSOVER: Texas Court Upholds Specific Jurisdiction Over Nonresident Based on Oral Agreement and Texas-Centered Performance—Template for Keeping Out‑of‑State Abusers/Spouses in Texas Family Courts

Padilla-Madden v. Sandoval, 04-25-00303-CV, March 11, 2026.

On appeal from the 73rd Judicial District Court, Bexar County, Texas.

Synopsis

The Fourth Court of Appeals affirmed denial of a nonresident’s special appearance where she traveled to San Antonio to execute a trust agreement and then exercised control over trust assets kept in a San Antonio safe deposit box. Those Texas-centered acts were purposeful availment, and they “arose from or related to” the plaintiff’s breach-of-oral-agreement claim tied to her retention and compensation as trustee.

Relevance to Family Law

For Texas family-law litigators, this opinion is a jurisdictional blueprint for keeping out-of-state spouses, paramours, fiduciaries, or third-party “helpers” in Texas when the operative dispute is anchored to Texas performance—especially where the nonresident physically comes to Texas to execute documents, attends Texas meetings, or manages/controls property located here. In divorce, custody, and property litigation, Padilla-Madden supports specific jurisdiction over a nonresident who inserts themselves into Texas-centered financial arrangements (trusts, community-property-like asset management, safe-deposit boxes, business interests) and later claims “I’m not a Texas defendant” when sued for breach, fraud, fiduciary misconduct, reimbursement, or related economic claims.

Case Summary

Fact Summary

Cristian Sandoval, a Texas resident, sued Wendy Padilla-Madden, an Alabama resident, for breach of an alleged oral agreement. Sandoval claimed that he provided Madden the opportunity to be appointed trustee for a third party’s trust (the “Gan Shares Trust”), and that in exchange Madden agreed to pay him one-half of her trustee compensation. Sandoval alleged Madden later failed to pay $350,000 owed under that arrangement.

Jurisdiction turned on what Madden did in Texas. The record showed Madden traveled to San Antonio for meetings and to execute the Gan Shares Trust Agreement. After her appointment, she took possession and exercised control over trust assets—specifically shares of stock maintained in a safe deposit box located in San Antonio. Madden disputed the existence/characterization of the oral agreement, but she admitted she paid Sandoval $500,000 after earning $1,000,000 in trustee compensation; her alternative explanation (payment for a marketing study that “didn’t occur”) was not credited for special-appearance purposes.

The trial court denied Madden’s special appearance. The Fourth Court affirmed, concluding Texas had specific jurisdiction.

Issues Decided

• Whether Madden purposefully availed herself of the privilege of conducting activities in Texas through (i) travel to San Antonio to execute the trust agreement and attend meetings, and (ii) management/control of trust assets held in a Texas safe deposit box.
• Whether Sandoval’s breach-of-contract claim “arose from or related to” those Texas contacts sufficient to support specific jurisdiction.
• Whether exercising Texas jurisdiction would offend traditional notions of fair play and substantial justice.

Rules Applied

• Texas long-arm statute: A nonresident “does business” in Texas by contracting with a Texas resident when either party is to perform the contract in whole or in part in Texas. TEX. CIV. PRAC. & REM. CODE § 17.042(1).
• Due process/minimum contacts: Jurisdiction requires minimum contacts such that suit does not offend traditional notions of fair play and substantial justice. Int’l Shoe Co. v. Washington, 326 U.S. 310 (1945).
• Specific jurisdiction: Requires purposeful availment plus claims that arise from or relate to forum contacts. Ford Motor Co. v. Mont. Eighth Jud. Dist. Ct., 592 U.S. 351 (2021); Luciano v. SprayFoamPolymers.com, LLC, 625 S.W.3d 1 (Tex. 2021).
• Purposeful availment limits: Unilateral acts of others; random, isolated, fortuitous contacts are insufficient. (citing Hanson v. Denckla, 357 U.S. 235 (1958); and local authority).
• Relatedness standard: “Arises out of or relates to” includes causation and a non-causal but meaningful relationship, with “real limits.” Ford, 592 U.S. at 362; Moki Mac River Expeditions v. Drugg, 221 S.W.3d 569 (Tex. 2007).
• Special appearance burdens: Plaintiff pleads jurisdictional facts; burden shifts to defendant to negate all bases alleged. Kelly v. Gen. Interior Constr., Inc., 301 S.W.3d 653 (Tex. 2010).
• Fair play/substantial justice: Rarely defeats jurisdiction once minimum contacts shown; factors include burden, forum interest, efficiency, and policy. World-Wide Volkswagen Corp. v. Woodson, 444 U.S. 286 (1980); Guardian Royal Exch. Assur., Ltd. v. English China Clays, P.L.C., 815 S.W.2d 223 (Tex. 1991).

Application

The court treated this as a classic specific-jurisdiction dispute: not whether Madden had a continuous Texas presence, but whether her Texas-directed actions were deliberate and tethered to the suit’s operative facts.

On purposeful availment, the court emphasized that Madden’s contacts were not merely electronic or passive. She physically traveled to San Antonio to attend meetings and execute the trust agreement. Then, as trustee, she took possession of stock placed in a San Antonio safe deposit box—conduct reflecting intentional engagement with Texas as the locus of performance and asset control. Those are the kinds of “quality and nature” contacts that are difficult to reframe as random or fortuitous.

On relatedness, the court connected the dots between (1) the alleged oral agreement’s payment obligation and (2) Madden’s Texas-centered trustee role. Sandoval’s position was that Madden’s promise to share trustee compensation was contingent on her being retained and compensated as trustee. Her Texas contacts—executing the trust instrument in Texas and exercising control over Texas-located trust assets—were part of the operative story of how she became trustee, performed the trustee role, and earned the compensation that triggered the alleged obligation. Applying Ford’s “arise out of or relate to” framework, the court held the dispute sufficiently related to her Texas contacts, even as it carefully segregated jurisdictional analysis from ultimate merits.

Finally, the court rejected any “fair play and substantial justice” escape hatch. Given Texas’s interest in providing a forum for its residents and the Texas location of key witnesses/events tied to trustee retention and compensation, Madden did not make the “compelling case” required to render jurisdiction unreasonable.

Holding

The court held that Madden purposefully availed herself of Texas by traveling to San Antonio to execute the trust agreement and by managing trust assets located in a Texas safe deposit box—contacts that were neither random nor fortuitous.

The court further held that Sandoval’s breach-of-oral-agreement claim arose from or related to those Texas contacts because the alleged duty to pay was tied to Madden’s retention and compensation as trustee—events and performance significantly connected to Texas.

The court held that exercising jurisdiction over Madden did not offend traditional notions of fair play and substantial justice, and therefore affirmed the denial of Madden’s special appearance.

Practical Application

Texas family cases increasingly include interstate fact patterns: a spouse relocates; a paramour funds litigation; a parent “moves money” through a trust or an LLC; a third-party fiduciary controls assets; a nonresident signs a mediated settlement agreement (MSA)-adjacent instrument in Texas and later challenges enforcement. Padilla-Madden provides a clean, litigation-ready framework for pleading and proving specific jurisdiction in those cases.

Key strategic applications include:

1. Property enforcement and post-divorce disputes: When the out-of-state party came to Texas to sign a partition/exchange agreement, refinance paperwork, trust documents, or to retrieve/store property in a Texas safe deposit box, plead those physical and performance contacts as purposeful availment and link them to the enforcement claim.
2. Third-party and fiduciary targets: In cases involving marital property held in trusts, nominee arrangements, or “friendly trustee” structures, Padilla-Madden supports jurisdiction over the nonresident trustee/agent when they execute Texas documents, attend Texas meetings, or control Texas-situs assets—particularly where your claims track the “operative facts” of retention, compensation, control, and nonpayment.
3. Economic torts and contract claims joined to SAPCR/divorce: If you are asserting fraud, conspiracy, aiding-and-abetting, breach of fiduciary duty, or unjust enrichment against a nonresident who acted in Texas to facilitate concealment or control of assets, this case reinforces focusing the record on Texas-centered performance, not simply communications.
4. Defensive posture (special appearance risk management): For nonresident clients, this is the cautionary tale—physically coming to Texas to execute agreements and managing Texas-located assets is high-octane jurisdictional fuel. If avoiding Texas is a priority, structure performance and asset custody accordingly, document forum/venue clauses where appropriate, and avoid Texas-centered asset control.

Checklists

Pleading Specific Jurisdiction in a Texas Family-Adjacent Dispute

• Plead concrete Texas acts: in-person meetings in Texas, execution/signing in Texas, notary location, bank branch visits, safe-deposit access, asset delivery/possession in Texas.
• Tie each Texas act to an element/trigger of the claim (e.g., retention, compensation earned, control exercised, nonpayment due).
• Identify Texas-situs property (safe deposit box, Texas bank account, Texas real property, Texas-based entity records).
• Plead that performance occurred in Texas (in whole or in part) under TEX. CIV. PRAC. & REM. CODE § 17.042(1).
• Anticipate the “unilateral activity” defense and plead facts showing the nonresident’s own deliberate choices.

Building the Jurisdictional Record (Special Appearance Proof)

• Secure affidavits/declarations on: where documents were executed, where meetings occurred, who attended, and what was done in Texas.
• Obtain travel evidence: flight/hotel receipts, calendar invites, text messages confirming Texas meetings, building access logs where available.
• Subpoena safe-deposit/bank records: signature cards, access logs, branch location, custodial documentation, inventory/contents acknowledgments.
• Lock down admissions: deposition questions on the “why Texas?” decision, who requested travel, what was executed, what property was controlled, and where.
• Identify Texas witnesses critical to the underlying transaction (not just to jurisdiction) to support both relatedness and fair-play factors.

Framing the “Arise From or Relate To” Nexus (Moki Mac / Ford)

• Draft a simple timeline connecting Texas acts to the claim’s operative facts (e.g., appointment → execution in Texas → Texas asset control → compensation → nonpayment).
• Emphasize conditional obligations triggered by Texas-centered performance (like “only if retained/compensated” type terms).
• Avoid overreliance on emails/calls alone; prioritize Texas performance and Texas asset control.
• Use Ford language: jurisdiction can exist on a meaningful relationship even without strict but-for causation—while still showing real limits.

Defense Checklist: Reducing Texas Jurisdiction Exposure for Nonresident Parties

• Avoid executing key instruments in Texas; if unavoidable, document that performance, custody, and control occur elsewhere.
• Do not control/hold disputed assets in Texas (safe deposit boxes and Texas bank accounts are particularly visible hooks).
• Clarify who performs and where; document that performance is outside Texas when possible.
• Consider jurisdiction/venue provisions in enforceable agreements (recognizing they are not always dispositive in all family contexts).
• If sued, negate each pleaded jurisdictional basis with competent evidence; do not rely on generalized “I’m not a Texas resident” denials.

Citation

Padilla-Madden v. Sandoval, No. 04-25-00303-CV (Tex. App.—San Antonio Mar. 11, 2026) (mem. op.).

Full Opinion

Read the full opinion here

Family Law Crossover

In Texas divorce and custody litigation, Padilla-Madden can be weaponized as a jurisdictional retention tool when the opposing party (or an aligned third party) tries to litigate from out of state after leveraging Texas to execute the operative plan. The play is straightforward: plead and prove Texas-centered performance that is inseparable from the economic wrong—execution of instruments in Texas (trusts, entity documents, agreed property arrangements), in-person Texas meetings that operationalize control over marital or quasi-marital assets, and—most powerfully—custody/control of property maintained in Texas (safe deposit boxes, Texas accounts, Texas entity records). Then frame your claims (enforcement, reimbursement, fraud, fiduciary breach, conspiracy, turnover/constructive trust) around the same “operative facts” the court focused on here: the retention/appointment/compensation/control sequence that occurred through Texas. When done correctly, the nonresident’s “special appearance” becomes a merits-adjacent credibility fight they must win with evidence—rather than a residency checkbox they can win with geography.

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