Jurisdiction Based on Information Received by Phone Call

In Memorial Hospital System v. Fisher Insurance Agency, Inc., 835 S.W.2d 645 (Tex. App.--Houston [14th Dist.] 1992, no writ), the plaintiff hospital telephoned the defendant, a Mississippi insurance agency, to verify workers' compensation insurance coverage prior to admitting an injured worker. See 835 S.W.2d at 648. Relying on the Mississippi agency's affirmative response, the hospital admitted and treated the worker. See id. When it discovered that there was in fact no coverage, the hospital brought suit in Texas against the Mississippi agency. See id. The court of appeals affirmed jurisdiction in Texas because the specific representation in the call was relied upon in Texas. See id. In Brown v. Flowers Industries, Inc., 688 F.2d 328 (5th Cir. 1982), Brown alleged that he lost the chance to obtain a loan because of a defamatory statement made in a telephone call made by Karlis, an Indiana resident, from his office in Indiana to the United States Attorney in Mississippi. See 688 F.2d at 330-31.