Background
The Texas Fifteenth Court of Appeals officially opened for business on September 1, 2024, marking a significant structural expansion of the State’s intermediate appellate jurisdiction. On June 3, 2025, the newest Texas intermediate appellate court, the Fifteenth Court of Appeals, issued a little-noticed but highly consequential opinion in Ketan Mehta v. State of Texas ex rel. Tarik Ahmed (716 S.W.3d 186). This Court of Appeals’ first major personal jurisdiction holding delineates the limits of Texas’s constitutional exercise of personal jurisdiction over nonresident individual defendants, particularly over nonresident corporate officers.
The case arose from a lawsuit filed by the Office of the Texas Attorney General under the Texas Medicaid Fraud Prevention Act (TMFPA), the state’s analog to the Federal False Claims Act. The State alleged that two pharmaceutical companies — Tris Pharma, Inc. and Pfizer, Inc., submitted or caused the submission of false claims to Texas Medicaid for reimbursement of Quillivant XR, a medication allegedly adulterated due to out of specification quality-control manufacturing. Interestingly, the State also named Ketan Mehta, Tris’s New Jersey–based CEO, as an individual defendant.
See AG press release: https://www.texasattorneygeneral.gov/news/releases/attorney-general-ken-paxton-sues-drug-manufacturer-tris-pharma-defrauding-texas-taxpayers
Procedural History
Representing Mr. Mehta, I challenged the trial court’s jurisdiction, arguing that Texas courts lacked personal jurisdiction over him individually because he is a New Jersey resident who performed all relevant conduct outside of Texas. The 71st District Court in Harrison County (Marshall, TX) denied the special appearance, finding jurisdiction proper under the TMFPA. In other words, the trial court found that Mr. Mehta – as an individual – had established the sufficient minimum contacts with the State of Texas to subject him to personal jurisdiction in Texas.
On appeal, the recently created Fifteenth Court of Appeals reversed and rendered, holding that the trial court lacked personal jurisdiction over Mr. Mehta and dismissed all claims against him.
The Court’s Holding
Justice April Farris, writing for a unanimous panel that included Chief Justice Scott Brister and Justice Scott Field, delivered a reversal and rendition of dismissal. The Court of Appeals held that the State’s pleadings and evidence failed to establish that Mr. Mehta purposefully availed himself of the privilege of conducting activities in Texas, as required for specific personal jurisdiction.
The State alleged that Mr. Mehta directed the adulteration of Quillivant XR and knew it would ultimately reach Texas Medicaid patients. The Court of Appeals, however, emphasized that jurisdiction must rest on a defendant’s own contacts with Texas, not the unilateral acts of third parties such as Pfizer.
Key findings included:
- Mehta’s alleged misconduct—directing manufacturing changes—occurred in New Jersey, not Texas.
- The mere understanding that Pfizer would market and distribute the drug in Texas was insufficient to create jurisdiction.
- Sporadic emails and conversations with three Texas physicians over five years were “too attenuated” to constitute purposeful availment.
- There was no evidence Mehta personally communicated with the Texas Health and Human Services Commission or any state entity.
Significance of the Decision
This opinion is among the first substantive personal jurisdiction holdings from the Texas Fifteenth Court of Appeals, and it carries significant implications for multistate litigation under the Texas Medicaid Fraud Prevention Act and other statutory schemes that often involve out-of-state corporate officers.
By holding that mere foreseeability that a product will reach Texas is insufficient to confer jurisdiction, the court reinforced a strict application of the purposeful-availment requirement, aligning Texas law with the U.S. Supreme Court’s Walden v. Fiore framework.
Practically speaking, the decision provides a powerful precedent for nonresident executives defending against attempts by Texas plaintiffs—or the Attorney General—to hale them into Texas courts based solely on corporate affiliation or downstream product distribution.
Commentary
From a litigation strategy perspective, this outcome was, candidly, a hail-Mary—an aggressive jurisdictional challenge that relied on the Fifteenth Court’s likely emphasis on textualism and due-process rigor. That bet paid off.
The State had little substantive need to include the CEO as a defendant; the move appeared calculated to increase settlement pressure. The court’s dismissal decisively rejects that tactic and restores a meaningful jurisdictional boundary for individuals whose alleged actions occurred wholly outside Texas.
