Justia Texas Supreme Court Opinion Summaries

The Texas Attorney General alleged that Annunciation House, a nonprofit organization in El Paso, was unlawfully harboring illegal aliens. The Attorney General sought to examine the organization's records and initiate quo warranto proceedings, which could lead to the revocation of its charter. Annunciation House, which provides shelter to immigrants and refugees, was served with a records request by state officials, who demanded immediate compliance. Annunciation House sought legal relief, arguing that the request violated its constitutional rights.The 205th Judicial District Court in El Paso County granted a temporary restraining order and later a temporary injunction against the Attorney General's records request. The court also denied the Attorney General's motion for leave to file a quo warranto action, ruling that the statutes authorizing the records request were unconstitutional and that the allegations of harboring illegal aliens did not constitute a valid basis for quo warranto. The court further held that the statutes were preempted by federal law and violated the Texas Religious Freedom Restoration Act (RFRA).The Supreme Court of Texas reviewed the case on direct appeal. The court held that the trial court erred in its constitutional rulings and that the Attorney General has the constitutional authority to file a quo warranto action. The court emphasized that it was too early to express a view on the merits of the underlying issues and that the usual litigation process should unfold. The court also held that the statutes authorizing the records request were not facially unconstitutional and that the trial court's injunction against the Attorney General's records request was improper. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "PAXTON v. ANNUNCIATION HOUSE, INC." on Justia Law

The case involves a challenge to a Texas Department of Family and Protective Services (DFPS) rule that authorized state licenses for two residential facilities where the federal government detained mothers and children after their illegal entry into the United States. The plaintiffs, including detained mothers and Grassroots Leadership, Inc., sought to prohibit the detention of children at these facilities, arguing that the rule was invalid under state law. However, by the time the case reached the court of appeals, all the mothers and children had been released from the facilities.The trial court denied the pleas to the jurisdiction filed by the department and the facility operators, eventually ruling in favor of the plaintiffs by declaring the rule invalid and enjoining the department from granting licenses under it. The Third Court of Appeals reversed, holding that the plaintiffs lacked standing and that their claims were moot since they were no longer detained. However, the court of appeals proceeded to address the merits of the case by invoking the "public-interest exception" to mootness and held the rule invalid under the Administrative Procedure Act.The Supreme Court of Texas reviewed the case and held that Texas courts are not constitutionally authorized to adjudicate moot cases, even if they raise questions of considerable public importance. The court emphasized that mootness is a constitutional limitation on judicial power, and there is no "public-interest exception" to mootness in Texas. Consequently, the court reversed the court of appeals' judgment regarding its jurisdiction, vacated the judgment on the merits, and dismissed the case for lack of subject-matter jurisdiction. View "TEXAS DEPARTMENT OF FAMILY AND PROTECTIVE SERVICES v. GRASSROOTS LEADERSHIP, INC" on Justia Law

Cheryl Butler was hired as an assistant law professor at Southern Methodist University (SMU) in 2011. After a mandatory third-year performance review, her contract was renewed, and she became eligible for tenure consideration in the fall semester of 2015. Due to illness, Butler requested an extension of the tenure vote, which was denied, but she was later granted leave under the Family Medical Leave Act (FMLA) for the spring semester of 2016. Her tenure committee, chaired by Professor Roy Anderson, concluded that Butler met tenure standards for scholarship and service but not teaching. Consequently, the law faculty voted not to recommend tenure, and Butler's appeals to the SMU Law School Dean and the Provost were unsuccessful. Butler completed the 2016-2017 academic year without teaching any classes.Butler filed a lawsuit against SMU and several of its employees, alleging racially discriminatory tenure standards and processes, and retaliation for her internal complaints about race, disability, and FMLA discrimination. She brought federal statutory claims under 42 U.S.C. § 1981, Title VII of the Civil Rights Act of 1964, the Rehabilitation Act of 1973, the Americans with Disabilities Act, Title IX, and the FMLA. Additionally, she asserted state-law discrimination and retaliation claims under Texas Labor Code Chapter 21, along with state common law claims for breach of contract and negligent supervision. Against the employee defendants, she claimed defamation, conspiracy to defame, and fraud.The United States District Court for the Northern District of Texas dismissed Butler's defamation and fraud claims against the employee defendants, citing preemption by Chapter 21 of the Texas Labor Code. The court held that the gravamen of these claims was unlawful employment discrimination and retaliation, which Chapter 21 specifically addresses. Butler appealed, and the United States Court of Appeals for the Fifth Circuit certified a question to the Supreme Court of Texas regarding whether Chapter 21 preempts common law defamation and fraud claims against employees based on the same conduct as discrimination claims against the employer.The Supreme Court of Texas held that Chapter 21 does not preempt common law defamation and fraud claims against employees. The court reasoned that Chapter 21 subjects only employers to liability for discriminatory and retaliatory conduct and does not immunize individuals from liability for their own tortious actions. Therefore, Butler's defamation and fraud claims against the employee defendants are not foreclosed by Chapter 21. View "BUTLER v. COLLINS" on Justia Law

American Pearl Group, L.L.C., John Sarkissian, and Andrei Wirth (collectively, “Pearl”) and National Payment Systems, L.L.C. (“NPS”) operate in the credit-card-payment-processing industry. In May 2019, NPS loaned $375,100.85 to Pearl, to be repaid with interest over forty-two months. The Loan Agreement required Pearl to pay back $684,966.76, with a schedule allocating each month’s payment between principal and interest. Pearl sued NPS in March 2022, seeking a declaration that the Loan and Option Agreement violated Texas usury law.The U.S. District Court for the Northern District of Texas granted NPS’s motion to dismiss, concluding that the scheduled interest payments were not usurious under the “spreading doctrine,” the purchase option’s value was too uncertain to constitute interest, and Pearl had not adequately alleged a scheme to conceal usury. The district court calculated the interest by spreading it over the term of the loan in equal parts, finding no usury violation. Pearl appealed to the U.S. Court of Appeals for the Fifth Circuit, arguing that the district court erred by applying the “equal parts” method instead of the actuarial method required by Section 306.004(a) of the Texas Finance Code.The Supreme Court of Texas reviewed the case and held that Section 306.004(a) requires courts to calculate the maximum permissible interest based on the declining principal balance for each payment period, using the actuarial method. The court emphasized that the Legislature’s deliberate choice of words in the statute matters, and the actuarial method calls for interest amounts to be calculated for each payment period based on the declining principal balance. The court answered the Fifth Circuit’s certified question affirmatively, clarifying that the interest calculations must be based on the declining principal balance when periodic principal payments are provided during the loan term. View "AMERICAN PEARL GROUP, L.L.C. v. NATIONAL PAYMENT SYSTEMS, L.L.C." on Justia Law

Abigail Cerna and her child visited Urban Air Trampoline and Adventure Park in Pearland, Texas, on August 30, 2020. Upon entry, Cerna signed a release agreement that included a broadly worded arbitration clause covering disputes related to the scope, validity, and arbitrability of the agreement. The agreement did not specify its duration. On November 21, 2020, Cerna and her child returned to the park without signing another release. During this visit, Cerna's child was injured, and Cerna subsequently filed a lawsuit against Urban Air.The trial court denied Urban Air's motion to compel arbitration, arguing that the August agreement did not apply to the November visit. The Court of Appeals for the Fourteenth District of Texas reversed the trial court's decision. The appellate court held that the issue of whether the arbitration agreement extended to the second visit was a matter of scope, not existence. Since the parties had agreed to delegate scope-related issues to an arbitrator, the appellate court concluded that the trial court erred in not compelling arbitration.The Supreme Court of Texas reviewed the case and agreed with the appellate court's decision. The Supreme Court held that the question of the agreement's duration is a matter of scope, which the parties had delegated to an arbitrator. Since Cerna did not dispute the validity of the August agreement but only its applicability to the November visit, the Supreme Court affirmed the appellate court's judgment. The case was remanded to the trial court to issue an order compelling arbitration. View "CERNA v. PEARLAND URBAN AIR, LLC" on Justia Law

Hurricane Harvey caused significant flooding in Texas in 2017. Homeowners in Matagorda County sued Tenaris Bay City Inc., a nearby pipeline manufacturing company, alleging that design defects at its facility caused flood damage to their homes. The plaintiffs claimed negligence, gross negligence, negligence per se, and negligent nuisance. The district court ruled in favor of the plaintiffs, and the court of appeals affirmed the decision.The district court directed a verdict on gross negligence in favor of Tenaris but submitted the other negligence theories to the jury. The jury found Tenaris liable on all three negligence theories, and the district court rendered judgment for $2.8 million plus interest. Tenaris appealed, and the court of appeals affirmed the judgment.The Supreme Court of Texas reviewed the case, focusing on whether the plaintiffs proved that Tenaris's negligence was the cause of the flooding. The court concluded that there was legally insufficient evidence to show that the plaintiffs' homes would not have flooded but for Tenaris's actions. The plaintiffs' expert witness admitted he had not conducted the necessary scientific analysis to determine the cause of the flooding at the specific properties. The court emphasized that in cases of catastrophic rainfall, proving causation requires reliable evidence that the defendant's actions were the but-for cause of the damage.The Supreme Court of Texas reversed the judgments of the lower courts and rendered judgment for Tenaris, holding that the plaintiffs failed to prove that their flood damage would not have occurred without Tenaris's alleged negligence. View "TENARIS BAY CITY INC. v. ELLISOR" on Justia Law

David W. Cromwell and Anadarko E&P Onshore, LLC are co-tenants in an oil-and-gas lease on land in Loving County, Texas. Cromwell obtained his interests in 2009 through two leases, one with Carmen Ferrer and one with the Tantalo Trust. Both leases contained habendum clauses that extended the lease terms as long as minerals were produced from the land. Anadarko, which already had a working interest and had drilled wells on the land, continued to produce minerals. Cromwell repeatedly sought to participate in production and enter a joint operating agreement with Anadarko, but Anadarko did not respond. Despite this, Anadarko sent Cromwell joint interest invoices and treated him as a working interest owner.The trial court granted summary judgment in favor of Anadarko, ruling that Cromwell's leases terminated at the end of their primary terms because he did not personally cause production. The Court of Appeals for the Eighth District of Texas affirmed, holding that Cromwell was required to take action to cause production to keep his leases alive, based on the court's previous decision in Cimarex Energy Co. v. Anadarko Petroleum Corp.The Supreme Court of Texas reviewed the case and held that the plain language of the habendum clauses did not require Cromwell to personally produce minerals to maintain his interests. The court emphasized that the leases did not specify who must produce the minerals and that production in commercial paying quantities had continuously occurred on the land. Therefore, Cromwell's leases did not terminate. The court disapproved of previous decisions that required lessees to personally produce minerals when the lease language did not explicitly state such a requirement. The judgment of the court of appeals was reversed, and the case was remanded to the trial court to address the parties' remaining arguments. View "CROMWELL v. ANADARKO E&P ONSHORE, LLC" on Justia Law

Renaissance Medical Foundation (the Practice) is a nonprofit health organization certified by the Texas Medical Board. The Practice employed Dr. Michael Burke, a neurosurgeon, to provide medical services to its patients. Rebecca Lugo brought her daughter to Doctors Hospital at Renaissance for brain surgery performed by Dr. Burke. The surgery resulted in permanent neurological damage to Lugo’s daughter. Dr. Burke later expressed that a retractor used during the procedure migrated into the child’s brainstem, causing the injury. Lugo filed a lawsuit alleging negligence by Dr. Burke and sought to hold the Practice vicariously liable for his actions.The trial court denied the Practice’s motion for summary judgment, which argued that it could not be held vicariously liable for Dr. Burke’s negligence because it did not control the manner in which he provided medical care and that Dr. Burke was an independent contractor. The court concluded that Dr. Burke’s employment agreement granted the Practice sufficient control over him to trigger vicarious liability. The court authorized a permissive interlocutory appeal of the ruling.The Court of Appeals for the Thirteenth District of Texas affirmed the trial court’s decision, holding that Dr. Burke was an employee of the Practice under traditional common-law factors and was acting within the scope of his employment when the alleged negligence occurred. The Practice then filed a petition for review with the Supreme Court of Texas.The Supreme Court of Texas held that a nonprofit health organization may not be held vicariously liable if exercising its right of control regarding the alleged negligence would interfere with its employee physician’s exercise of independent medical judgment. The court concluded that the Practice did not conclusively demonstrate such interference and affirmed the denial of the Practice’s motion for summary judgment, remanding the case for further proceedings. View "RENAISSANCE MEDICAL FOUNDATION v. LUGO" on Justia Law

Ireille Williams-Bush, a 35-year-old woman, was taken to Medical City Arlington Hospital with symptoms indicative of a pulmonary embolism. However, she was diagnosed with a non-ST-elevated myocardial infarction and admitted under that diagnosis. The consulting cardiologist did not screen her for a pulmonary embolism. She was discharged in stable condition but died three days later from clotting in her heart and lungs. Her husband, Jared Bush, sued the hospital and associated physicians for negligence, focusing on the hospital's failure to have adequate protocols to ensure proper diagnosis and treatment.The trial court initially found the expert report by Dr. Cam Patterson, which supported Bush's claims, to be adequate. However, the Court of Appeals for the Second District of Texas reversed this decision, deeming the report conclusory regarding causation and dismissing the claims against the hospital with prejudice. The appellate court held that the expert's opinions did not sufficiently explain how the hospital's policies could have influenced the medical decisions made by the physicians.The Supreme Court of Texas reviewed the case and held that the trial court did not abuse its discretion in finding the expert report adequate. The court concluded that Dr. Patterson's report provided a fair summary of the standard of care, the hospital's breach, and the causal relationship between the breach and Williams-Bush's death. The Supreme Court reversed the judgment of the court of appeals and remanded the case to the trial court for further proceedings. View "BUSH v. COLUMBIA MEDICAL CENTER OF ARLINGTON SUBSIDIARY, L.P." on Justia Law

This case involves a dispute between American Midstream (Alabama Intrastate), LLC (AMID) and Rainbow Energy Marketing Corporation (Rainbow) over a contract (MAG-0005) for the transportation and balancing of natural gas. Rainbow had contracts to transport gas through two interconnected pipelines, the Transco and the Magnolia, and used the MAG-0005 to leverage AMID’s balancing flexibility. The contract allowed Rainbow to run imbalances, withdrawing gas without simultaneously supplying an equal amount, provided they resupplied by the end of each month. Disputes arose when Transco began limiting imbalances more strictly, leading to AMID curtailing Rainbow’s nominations on several occasions.The trial court found in favor of Rainbow on all its claims, including breach of contract, repudiation, fraud, fraudulent inducement, and negligent misrepresentation, awarding over $6 million in lost profits. The court interpreted Section 9.1 of the MAG-0005 as excusing AMID’s performance only under specific conditions involving scheduled and physical imbalances. The Court of Appeals for the First District of Texas affirmed the trial court’s decision, agreeing with its interpretation of the contract and the award of damages.The Supreme Court of Texas reviewed the case and held that the trial court had erroneously inserted language into Section 9.1 of the MAG-0005. The correct interpretation of Section 9.1 excused AMID from providing balancing services on any day that Transco required AMID or Rainbow to limit imbalances attributable to Rainbow, without distinguishing between types of imbalances. The Supreme Court reversed the lower courts' decisions, rendered judgment for AMID on Rainbow’s contract-repudiation and tort claims, and remanded for a new trial on the breach-of-contract claims to determine if Transco mandates excused AMID’s performance on the days in question. View "AMERICAN MIDSTREAM (ALABAMA INTRASTATE), LLC v. RAINBOW ENERGY MARKETING CORPORATION" on Justia Law