Here’s a detailed analysis of the case In re Greyhound Lines, Inc., decided by the Texas Supreme Court on May 23, 2025. You can read the full text of the opinion by clicking here.
The case centers on a tragic bus crash in Mexico involving Maria Granados, a Mexican citizen and Alabama resident, who died in the accident. Maria’s son sued Greyhound Lines, Estrella Blanca (a Mexican bus company), and the bus driver in Texas for multiple claims, including breach of contract, fraud, negligence, and wrongful death. The core dispute concerns whether the Texas court should dismiss the case on forum non conveniens grounds—meaning, whether it should defer to a more appropriate foreign forum (Mexico) given the case’s connections.
Key Facts:
- Maria’s trip was booked via Greyhound, a Texas-based company, but the crash happened on a Mexican bus operated by Estrella Blanca.
- Estrella Blanca controls its own routes and employees; the bus driver was an Estrella Blanca employee, a Mexican resident who fled after the accident.
- The Granados family sued in Texas, but Greyhound argues Mexico is the proper forum.
- Greyhound stipulates it will submit to Mexican court jurisdiction and waive statute of limitations defenses there.
- The trial court originally denied Greyhound's motion to dismiss, citing concerns about Mexican courts’ jurisdiction, adequacy, and procedural hurdles.
Legal Framework:
Texas law requires courts to dismiss or stay a case if it’s in the interest of justice and convenience to hear it elsewhere. The court must weigh six factors:
- Whether an alternate forum exists where the case may be tried.
- Whether that forum provides an adequate remedy.
- Whether maintaining the case in Texas would cause substantial injustice.
- Whether the alternate forum can exercise jurisdiction over all defendants.
- The balance of private and public interests favoring the alternate forum.
- Whether dismissal would cause unreasonable duplication of litigation.
Court’s Analysis:
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Alternate Forum Exists: Mexico qualifies because the defendant agrees to jurisdiction and waiver of limitations. Prior Texas cases support Mexico as an available forum for accidents occurring there.
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Adequate Remedy: Mexican law, while different (e.g., no punitive damages, no jury trial), still provides a remedy. The court rejects arguments that procedural differences make Mexico inadequate.
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Substantial Injustice: Most witnesses and evidence are in Mexico. Texas courts lack compulsory process over many key witnesses, making Texas an inconvenient and unjust forum for trial.
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Jurisdiction Over Defendants: Mexican courts can exercise jurisdiction over Estrella Blanca and the driver, and Greyhound consents to Mexican jurisdiction.
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Balance of Interests: Private interests (ease of access to evidence, convenience) and public interests (local interest in adjudicating local accidents, application of Mexican law) favor Mexico.
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No Unreasonable Duplication: The Granados family’s litigation progress in Texas does not justify denying dismissal, especially since the motion was timely.
Additional Points:
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Greyhound’s crossclaim against Estrella Blanca for indemnity does not waive its forum non conveniens challenge nor judicially admit Texas as the proper forum.
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The trial court abused its discretion by denying the motion to dismiss based on forum non conveniens.
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The Texas Supreme Court conditionally grants mandamus relief ordering dismissal, subject to conditions ensuring fairness (such as Mexican courts accepting jurisdiction).
Bottom Line:
The Texas Supreme Court ruled that the case should be dismissed in favor of Mexico as the proper forum. Even though the plaintiff preferred Texas and there’s a Texas-based defendant, the location of the accident, witnesses, and applicable law strongly tilt the balance toward Mexico. The court carefully applied statutory factors and concluded that fairness and judicial efficiency demand the case be heard there.
Girards Law Firm specializes in severe injury and wrongful death cases, especially those that involve brain damage, heart damage, spinal cord injuries or severe burns in Texas, Arkansas and Oklahoma. Contact us at www.girardslaw.com by using the chat feature for more information.