Texas Business Court Clarifies Jurisdictional Threshold And "Qualified Transaction" Requirements

The Texas Business Court continues to develop precedent regarding its own jurisdiction. In Angela Yaun v. Battle & Sands Energy Corp., et al., Cause No. 25-BC11B-0094 (Tex. Bus. Ct. Mar. 3, 2026), Judge Grant Dorfman of the Eleventh Division (in Houston) denied a plaintiff's motion to remand, providing guidance on two key jurisdictional questions: what constitutes a "qualified transaction," and which dollar threshold applies following recent legislative changes.

Background and Key Facts

Angela Yaun brought suit against Battle & Sands Energy Corporation and related defendants, alleging they breached an agreement to pay her a perpetual royalty of $1.00 per ton on frac sand sold from a quarry in Beeville, Texas. Her claims included breach of contract, equitable estoppel, quasi-estoppel, fraud, and statutory relief under the Texas Sales Representative Act (TSRA). The defendants removed the case to the Texas Business Court under Texas Government Code § 25A.004(d)(1).