Samuel Grant Dorfman
How Judge Dorfman decides
Patterns drawn from this judge's own signed orders. Every observation links to the order it came from.
What persuades
On the Business Court's own enabling statute, he construes the September 1, 2024 commencement-date limit strictly and reads the enrolled-bill text (rather than any later codification gap) as controlling, applying multiple textual canons together (surplusage, expressio unius, and the presumption against retroactivity) to hold that non-consensual removal is barred for any case filed before that date, no matter how well the underlying dispute otherwise fits the court's subject-matter jurisdiction.
“So Defendants' reading of Section 8 renders its date reference at best superfluous, and possibly a nullity-contrary to the canon that presumes the entirety of a statute is intended to have effect.”
Procedural preferences
At the jurisdictional-threshold stage, he applies the burden-shifting standard generously toward the party invoking jurisdiction: a good-faith damages allegation controls unless disproven, and even an admittedly rough plaintiff-side damages estimate can plausibly clear the qualified-transaction and amount-in-controversy floor without requiring the party to marshal conclusive proof this early in the case.
“the evidence before the Court plainly establishes the possibility—plausibility, even—that Yaun's damages claim could satisfy the Business Court's jurisdictional minimum for a qualified transaction”
He enforces mandatory venue statutes over contractual venue-selection clauses, looking to the 'essence' of the dispute rather than how a party has pleaded it; a declaratory-judgment claim framed as purely contractual will still be treated as an action affecting real property (triggering mandatory county-of-property venue) if its practical effect is to shield a party from real-property damages liability.
“At its essence, then, this dispute concerns the attempted recovery of damages to real property, which necessitates transfer to Loving County.”
Cautions
On whether a series of historical transactions is sufficiently 'related' to support qualified-transaction jurisdiction, he requires a genuine tie to the transaction actually in controversy -- decades of past purchase orders under the same umbrella agreement, involving different scopes of work or affiliated entities, are only background evidence of a long business relationship, not part of the relevant 'series,' and unsupported hearsay about their aggregate value will be excluded rather than presumed.
“They are, in short, historical background: evidence of a long-standing business relationship between the parties, but nothing more than that with respect to the subject matter of this suit.”
Signed rulings
A grounded sample of orders signed by this judge, with the verbatim dispositive language.
“For the foregoing reasons, the Court lacks authority to hear this case. Plaintiff's Motion to Remand is hereby GRANTED, and the Court hereby directs the Business Court Clerk to remand this cause to the 133rd Judicial District Court of Harris County, Texas.”
“For the foregoing reasons, Defendants' Motion to Transfer Venue is hereby GRANTED. Although the Court offered additional time at the oral hearing for it to do so, NGL did not make an election pursuant to TEX. GOV'T CODE § 25A.006(b) or (c); and so the Court believes it lacks authority to transfer the case to Loving County. Accordingly, the Court dismisses this cause without prejudice.”
“The Court heard the Motion to Transfer Venue, Motion to Dismiss for Lack of Subject-Matter Jurisdiction, and Rule 91a Motion to Dismiss filed by Defendants' Lime Rock Resources V-A, L.P. (“Lime Rock”) and LRR Pecos Valley, LLC (“Pecos Valley”) ... Accordingly, the Court need not and does not address the two motions to dismiss.”
“Because the value of the perpetual royalty interest sought by Yaun in her Original Petition exceeds the $5 million jurisdictional floor for a qualified transaction, this Court has proper subject matter jurisdiction. ... Plaintiff's Motion to Remand is hereby DENIED.”
“Accordingly, the Court holds that it lacks jurisdiction over the case under Government Code Section 25A.004(d)(1) because the MSA and the invoice at issue, taken together, do not constitute “a transaction, or series of related transactions” that exceeds $5 million in consideration. ... For the foregoing reasons, Plaintiff's Motion to Remand is hereby GRANTED.”
Put Judge Dorfman's record to work
Ezel drafts and answers grounded in this exact profile: how Judge Dorfman actually rules, not a generic AI guess.
Opens in Ezel Pro. Every answer is grounded in Judge Dorfman's own signed orders and cites them.