Background
A motor vehicle accident occurred on September 1, 2023, in Terrebonne Parish, Louisiana. Ronald Brown, an employee of Star 3 Transportation driving a tractor-trailer carrying hazardous materials, allegedly made an illegal right turn that struck a vehicle driven by Brittney Medice, severely injuring her and her minor son. Medice claimed she was “totally free from any fault whatsoever” in causing the collision.
Medice filed suit against Star 3 Transportation, Inc., Star 3 Brokerage, LLC, and Brown in Harrison County, Texas—where Star 3 maintains its principal place of business. She asserted claims for negligence, negligence per se, negligent entrustment, vicarious liability, and gross negligence, arguing that Star 3 negligently trained and supervised Brown.
Star 3 moved to dismiss on forum non conveniens grounds, contending that Louisiana was the more appropriate forum for litigation. The trial court denied the motion in August 2025. Star 3 then sought mandamus relief in the appellate court.
The Court’s Holding
The Sixth Court of Appeals held that the trial court abused its discretion by denying the forum non conveniens motion. Applying the six statutory factors under Texas Civil Practice & Remedies Code § 71.051, the court found that all factors weighed in favor of dismissal to Louisiana.
The court found that Louisiana was an adequate alternate forum because both Medice and Star 3 were amenable to process there and Louisiana law provided a remedy for her injuries. As a condition of dismissal, Star 3 agreed to waive any prescription (statute of limitations) defense to ensure an adequate remedy. Maintaining the action in Texas would cause substantial injustice to Star 3 because the great majority of relevant witnesses and evidence—including the accident investigation, police reports, medical treatment records, and medical providers—were located in Louisiana beyond the subpoena power of Texas courts. Although Star 3 maintained corporate facilities in Texas, the crux of the case centered on the accident and resulting damages in Louisiana, not on Star 3’s Texas operations.
The court emphasized that private interest factors (access to evidence and witness availability) and public interest factors (injured parties being Louisiana residents, accident occurring on Louisiana roads, and Louisiana’s local interest) both favored Louisiana. Critically, the court stressed that non-resident plaintiffs receive “substantially less deference” for their choice of forum than Texas residents, distinguishing this case from typical forum selection disputes.
Key Takeaways
- When all statutory forum non conveniens factors favor another forum, trial courts must grant dismissal even if the defendant is a Texas resident or maintains Texas operations
- Location of accident, witnesses, and evidence is critical—when the majority are outside Texas subpoena power, dismissal is strongly favored
- Non-resident plaintiffs receive substantially reduced deference for their forum choice compared to Texas residents
- Trial courts can impose conditions on dismissal, such as waiving statute of limitations defenses, to ensure adequate remedy in the alternate forum
- The focus of claims and where harm occurred controls the analysis, not the defendant’s principal place of business
Why It Matters
This decision reinforces that Texas courts will rigorously apply the statutory forum non conveniens analysis and reverse trial courts that fail to properly weigh all six factors. For defendants sued in Texas courts over out-of-state accidents, the opinion provides a clear roadmap to dismissal when evidence and witnesses are primarily located elsewhere. The court rejected Medice’s argument that Star 3’s training and supervision functions in Texas made the Texas forum appropriate—instead focusing on where the actual accident and resulting damages occurred. This is particularly significant for transportation and trucking companies that may face multi-state litigation, as it establishes that they can successfully obtain dismissal to the accident location even when they have substantial Texas operations.
The opinion also clarifies that trial courts can condition dismissal on defendants’ agreement not to assert statute of limitations defenses, protecting plaintiffs’ substantive rights even as procedural access shifts to a more convenient forum. The ruling demonstrates that when a non-resident plaintiff chooses Texas as a forum but all statutory factors point elsewhere, courts must grant dismissal to serve the interests of justice and the convenience of the parties.