Gardemal v. Westin Hotel Co. 186 F.3d 588 (5t Cir. 1999) Westin was a parent corporation that owned a number of hotel chains including one in Mexico. Gardemal's husband drowned while at a Westin hotel in Mexico. She sued both the American Westin corporation, as well as the Mexican Westin corporation, in a Texas court. The Trial Court dismissed. Gardemal appealed. The Trial Court found that there was a lack of personal jurisdiction to sue Westin Mexico in Texas. The Court found that as a parent, Westin is a separate corporate entity from Westin Mexico and cannot be held liable for acts by its subsidiary. The Appellate Court affirmed. Gardemal argued that Westin Mexico was functioning as the alter ego of Westin. However the Appellate Court found that Westin maintained a separate corporate identity, and the two companies were not so intermingled that they were alter egos of each other. Under the alter ego doctrine, a parent corporation can be held liable for the acts of another if the subject corporation is organized or operated as a mere tool or business conduit. One of the major factors for establishing liability under this doctrine would be if Westin Mexico was undercapitalized, but there was no evidence of that in this case. Gardemal argued that Westin and Westin Mexico operated as a single business enterprise. However the Court didn't find evidence that this was the case. Under the single business enterprise doctrine, a corporation can be held liable for the acts of another if they are not operated as separate entities, but integrate their resources to achieve a common business purpose. The Court noted that Gardemal should go sue Westin Mexico directly in a Mexican court. Gardemal probably sued in the US because at the time Mexico had a damage cap of $25k for wrongful death. Since piercing the corporate veil done for reasons of equity, maybe it isn't right to do it when someone is just forum shopping?