Dallas Office Obtains Appellate Win for Bus Operator Client Based on Lack of Personal Jurisdiction

Dallas, Texas (June 12, 2025) – Dallas Partner Mark Cronenwett recently obtained a decision from the Texas Court of Appeals dismissing personal injury claims against his bus operator client based on lack of personal jurisdiction.

This case involves a bus accident that occurred in Utah on December 12, 2022. The plaintiffs were passengers traveling from Boise, Idaho, to Salt Lake City, Utah, on tickets purchased from Greyhound, a company that has its principal place of business in Dallas. Pursuant to an Interline Agreement with Greyhound, the actual passenger carriage was provided by a regional passenger bus operator, Western Trails Charters and Tours, LLC d/b/a Salt Lake Express (SLE). SLE does not provide passenger bus service in Texas and has no other operations here.

Near Tremonton, Utah, the bus driver allegedly lost control, causing the bus to flip onto its side, leading to alleged personal injuries.

SLE filed a “Special Appearance” to challenge Texas’ personal jurisdiction over it. SLE maintained that Texas courts did not have the authority to hear claims against us regarding an accident that happened in Utah, notwithstanding its contractual agreement with Greyhound in the Interline Agreement.

The plaintiffs argued that SLE’s ties to Greyhound in the Interline Agreement—such as ticketing arrangements and operational coordination—were enough to bring it into a Texas courtroom. However, the law requires more than that. Case law from the Texas Supreme Court specifies that there must be a “substantial connection” between Texas and the out-of-state accident to justify the exercise of personal jurisdiction over the foreign defendant.

The Court of Appeals carefully reviewed the facts and determined that the Interline Agreement was not a substantial factor in the events leading to the alleged accident in Utah. As a result, the claims against SLE were dismissed for want of jurisdiction.