Samuel Grant Dorfman
How Judge Dorfman rules, drawn from 5 signed orders. Every observation links to the order it came from.
About Judge Dorfman
Grant Dorfman joined the Texas Business Court’s Eleventh Division in September 2024 after appointment by Governor Greg Abbott. He previously served on two Harris County district courts and as deputy first assistant attorney general of Texas. He earned degrees from Brown University, Oxford University, and Yale Law School.
Judge Dorfman's practices and standing orders
Rules for cases before Judge Dorfman, as published on the court's website (checked October 11, 2026). Judges revise these often, so confirm the current version on the court's site before you file.
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
In Yaun v. Battle & Sands Energy Corp., Judge Dorfman denied remand after finding that the claimed perpetual royalty plausibly exceeded the Business Court’s $5 million jurisdictional threshold at this preliminary stage.
“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”
In NGL Water Solutions Permian, LLC v. Lime Rock Resources V-A, L.P., Judge Dorfman treated a declaratory-judgment dispute as one affecting real property and transferred it to Loving County under the mandatory venue rule.
“At its essence, then, this dispute concerns the attempted recovery of damages to real property, which necessitates transfer to Loving County.”
Cautions
In Clean-Co Systems, Inc. v. Enterprise Products Operating, LLC, Judge Dorfman treated older purchase orders as background to the business relationship rather than part of the qualified transaction at issue.
“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.”
“The Court DENIES Defendants’ motion for summary judgment on the ground that Plaintiff lacks associational standing to pursue its direct causes of action against Defendants. The Court GRANTS Defendants’ motion regarding Plaintiff’s lack of standing to pursue the Derivative Claims under TEX. BUS. ORGS. CODE §20.002(c), and hereby DISMISSES the Derivative Claims against all Defendants.”
“The Court GRANTS IN PART Plaintiff’s Motion for Partial Summary Judgment and hereby DECLARES the 2023 amendment to Article V of the Church’s Articles of Incorporation is invalid and ineffective. In all other respects, Plaintiff’s Motion for Partial Summary Judgment is hereby DENIED.”
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