Texas Appeals Court Dismisses Claims Against Colorado Notary in Bexar County Land Fraud Case

Estella and Michael Martinez owned a vacant parcel of earth in Bexar County, Texas, until heavy machinery rolled in and strangers began laying the foundation of a house they never authorized.

An unidentified woman had impersonated the couple, staged a fraudulent sale, and executed a bogus deed on January 11, 2023, conveying the land to ABMF, LLC. One day later, the deed was recorded in Bexar County. The notarization bore the stamp of Skipton S Reynolds—a Colorado attorney and notary operating out of Arapahoe County. But when the Martinezes sued Reynolds for failing to verify the seller's true identity, the legal battle collided with the outer limits of state sovereignty.

Publishing its opinion on November 10, 2026, the Texas Fourth Court of Appeals dismantled the lower court's stance, ruling that Texas judges hold no personal jurisdiction over Reynolds because his official acts took place entirely within Colorado borders.

Phantom Sales and Skeletons of Concrete

The fraud unravelled purely by chance. Construction crews from Vena Homes, LLC, contracted by ABMF, had already begun raising structural frames on the Martinezes' lot before anyone detected the swindle.

The Martinezes confronted the builders immediately. They had signed nothing. They had sold nothing. The deal was an outright fabrication.

Faced with clear evidence of identity theft, construction ground to an immediate halt. ABMF executed a quitclaim deed to surrender any purported legal title and returned the lot directly to the Martinezes. Yet the administrative damage lingered. Litigation erupted over how an out-of-state notary allowed the scheme to materialize in the first place, with ABMF and the landowners seeking damages against Reynolds for gross professional negligence.

Reynolds pushed back aggressively. Mounting a special appearance in the 45th Judicial District Court of Bexar County, Reynolds argued that Texas courts held zero authority over him. He testified that his notarial credentials had been stolen, insisting an imposter had commandeered his stamp. Even if he had signed the document, Reynolds argued, executing an acknowledgment in Arapahoe County did not equate to purposeful business conduct in Texas.

The district court denied his challenge. Reynolds appealed.

Colorado Signature, Texas Soil: The Jurisdictional Fault Line

Writing for the Fourth Court of Appeals, the panel reversed the Bexar County court and dismissed all claims against Reynolds. The central legal question did not hinge on whether the deed was bogus—the fraud was uncontested. The pivot rested entirely on specific personal jurisdiction.

ABMF argued that by notarizing a conveyance intended to pass Texas land, Reynolds actively propelled a fraudulent transfer within the state. But the appellate judges rejected that nexus. Merely notarizing an instrument involving out-of-state real estate at the behest of another party does not constitute purposeful availment of Texas law, the bench concluded. Reynolds did not solicit the transaction. He derived no ownership stake in the Bexar County soil. Most critically, his duty of identity verification occurred exclusively within Colorado.

Yet the appellate ruling offers no clean exoneration of the underlying transaction itself. The court made clear its dismissal does not validate the January 2023 deed nor disprove that criminal impersonation occurred. It simply forecloses Texas courtrooms as the venue to hold Reynolds accountable, leaving any future negligence or credential-theft proceedings to the courts and regulators of Colorado.