The Texas Business Court continues to acknowledge its jurisdictional reach in commercial disputes. In Alamo Title Company v. WFG National Title Company of Texas, LLC, 2026 Tex. Bus. 6 (4th Div. Feb. 3, 2026), Judge Stacy Rogers Sharp denied a motion to remand, holding that the court had jurisdiction over claims arising from an alleged employee “raid” and misappropriation of salary details, customer lists, and other confidential business information. This opinion offers guidance on how the Business Court analyzes both the $5 million amount in controversy requirement and the topical prerequisites for jurisdiction.

Background and Key Facts

Alamo Title Company sued WFG National Title Company, alleging that WFG orchestrated a coordinated effort to poach Alamo’s employees and customers. According to the petition, the scheme began with Alamo’s president, Edward Hall, who allegedly reached an agreement with WFG to solicit employees and transfer sensitive business information—including customer lists, client files, and compensation details—to WFG for competitive advantage.

Alamo asserted claims for tortious interference with existing and prospective customer contracts, conspiracy, and aiding and abetting breach of fiduciary duties. The case was initially filed in Bexar County district court, but WFG removed it to the Texas Business Court. Alamo then moved to remand, arguing the court lacked jurisdiction.

The Court’s Analysis

Amount in Controversy

Under Chapter 25A of the Texas Government Code, the Business Court requires an amount in controversy exceeding $5 million. The court applied a burden-shifting framework: when a removal notice pleads a sufficient amount, the burden then shifts to the party seeking remand to provide evidence that the amount is $5 million or less, or that the pleading is fraudulent.

WFG’s removal notice alleged more than $5 million in controversy. Alamo offered no rebutting evidence and refused to acknowledge that the amount in controversy was less than $5 million. Instead, Alamo’s discovery responses disclosed $4.7 million in damages “for the year 2025,” with ongoing and increasing losses, plus claims for unjust enrichment and harm to reputation and goodwill that Alamo described as impossible to measure in monetary terms. Alamo denied a request for admission seeking affirmation that it would not seek to recover more than $5 million.

The court refused to allow Alamo to take an ambiguous and/or wait and see approach regarding the amount in controversy. The court emphasized that future damages count toward the jurisdictional threshold when pleaded at the time of removal, especially when Alamo refused to acknowledge that it would not seek recovery over $5 million. With no evidence contradicting WFG’s pleading, the amount in controversy requirement was satisfied.

Topical Jurisdiction: Two Independent Bases

Breach by a Managerial Official. Under Section 25A.004(b)(5), the Business Court has jurisdiction over actions alleging that a “controlling person or managerial official breached a duty owed to an organization… by reason of the person’s status.” Alamo’s petition expressly alleged that WFG aided and abetted Hall—Alamo’s president—in breaching his fiduciary duties. Because those duties arose from Hall’s role as a managerial official, this statutory prong was satisfied.

Intellectual Property Ownership or Use. Section 25A.004(d)(4) grants jurisdiction over actions “relating to the ownership, use, licensing, lease, installation, or performance of intellectual property,” including trade secrets. The court noted that Alamo’s petition repeatedly referenced misappropriation of “sensitive business information,” including customer lists and compensation data. Although Alamo did not assert a standalone trade secret claim, the “relating to” language requires only a connection—not a causal link—to intellectual property. The court found the petition’s allegations were “central, not tangential” to the case.

Jurisdiction Extends to the Entire Suit

The court confirmed that once a statutory basis for jurisdiction is established, the Business Court’s authority extends to the entire lawsuit—not just specific claims. The parties did not contend, and the Business Court did not find, that the dispute involved any of the restricted topics in Texas Government Code Section 25.004(g) or (h). This aligns with recent appellate guidance from the Fifteenth Court of Appeals that has declined to read the Legislature’s jurisdictional grant in Section 25A.004(b) as limited to itemized claims.

Practical Takeaways for Businesses

This opinion offers several lessons:

  • Employee mobility disputes may trigger Business Court jurisdiction. Cases involving alleged employee raiding, breach of fiduciary duties by officers, or misuse of confidential information may fall within the court’s purview.
  • Trade secret allegations matter—even without a standalone claim. The broad “relating to” standard means that repeated references to confidential information or intellectual property may invoke Business Court jurisdiction.
  • Be mindful of the amount in controversy. Parties opposing removal may wish to be prepared to offer concrete evidence stipulating that they are not seeking more than $5 million in damages. The Business Court does not seem inclined to take a wait and see approach regarding the plaintiff’s alleged damages, especially when the plaintiff does not acknowledge that it will not seek more than $5 million. Admissions of ongoing harm or incalculable losses may undermine remand arguments.
  • Future damages count. Claims for prospective harm are included in the jurisdictional calculus.
  • Invoke the Texas Business Court in Employment Agreements. Especially for employment agreements regarding C-Suite employees and/or employees with access to sensitive company information, it may be appropriate to stipulate venue in the Texas Business Court so as to avoid the added cost of a jurisdictional disputes.

Alamo Title Company v. WFG National Title Company reinforces the Texas Business Court’s willingness to find jurisdiction in commercial disputes involving executive misconduct and proprietary information. Companies facing—or contemplating—similar claims should carefully consider whether the Business Court may be the appropriate forum.