Justia Texas Supreme Court Opinion Summaries

During Winter Storm Uri in February 2021, extreme weather conditions in Texas led to record electricity demand and severe power shortages. The Electric Reliability Council of Texas (ERCOT) declared a "Level 3 Emergency" and ordered transmission and distribution utilities (the "Utilities") to cut power to some customers, resulting in widespread outages. Plaintiffs alleged that the Utilities' actions during the storm, including failing to rotate blackouts and cutting power to critical infrastructure, worsened the crisis and violated common-law duties.The plaintiffs filed numerous lawsuits against various participants in the Texas electricity market, including the Utilities, asserting claims of negligence, gross negligence, and nuisance. The cases were consolidated into a multidistrict litigation pretrial court, which dismissed some claims but allowed the gross-negligence and intentional-nuisance claims against the Utilities to proceed. The Utilities sought mandamus relief from the court of appeals, which granted partial relief by dismissing some claims but allowing the gross-negligence and intentional-nuisance claims to continue.The Supreme Court of Texas reviewed the case and held that the plaintiffs' pleadings did not sufficiently allege that the Utilities "created" or "maintained" a nuisance, leading to the dismissal of the intentional-nuisance claims with prejudice. The court also found that the pleadings were insufficient to support gross-negligence claims but allowed the plaintiffs an opportunity to replead these claims in light of the court's guidance. The court conditionally granted mandamus relief, ordering the trial court to vacate its previous order and dismiss the intentional-nuisance claims while permitting the plaintiffs to amend their gross-negligence claims. View "IN RE ONCOR ELECTRIC DELIVERY CO. LLC" on Justia Law

American Oversight, a nonprofit group, filed a petition for a writ of mandamus in district court against the Governor and the Attorney General of Texas, alleging violations of the Public Information Act (PIA). They sought official communications and other documents, which the Governor's and Attorney General's offices partially withheld, citing various exemptions. Dissatisfied with the responses, American Oversight pursued legal action to compel the release of the information.The Travis County district court denied the State's pleas to the jurisdiction, leading to an interlocutory appeal. The State argued that the district court lacked jurisdiction to issue a writ of mandamus against constitutional executive officers, as only the Texas Supreme Court has such authority under section 22.002(c) of the Texas Government Code. The court of appeals affirmed the district court's decision, holding that section 552.321(b) of the PIA authorized district courts to issue mandamus relief against any governmental body, including those headed by constitutional executive officers.The Supreme Court of Texas reviewed the case and concluded that section 552.321(b) did not expand the jurisdiction of district courts to issue writs of mandamus against constitutional executive officers. The Court held that only the Texas Supreme Court has the authority to issue such writs against these officers, as per section 22.002(c) of the Texas Government Code. Consequently, the Supreme Court of Texas reversed the judgment of the court of appeals and directed the district court to dismiss the mandamus petition for lack of jurisdiction. View "PAXTON v. AMERICAN OVERSIGHT" on Justia Law

Southern Methodist University (SMU), a nonprofit corporation, was founded by predecessors to the South Central Jurisdictional Conference of the United Methodist Church (the Conference). Historically, SMU’s articles of incorporation indicated that the university was owned and controlled by the Conference, requiring Conference approval for amendments. In 2019, SMU’s board of directors amended the articles without Conference approval, removing all references to the Conference. The Conference sued, seeking a declaration that the amendments were void and asserting claims for breach of contract and filing a materially false instrument.The trial court dismissed the Conference’s claims for declaratory judgment and breach of contract under Texas Rule of Civil Procedure 91a and granted summary judgment on the false-filing claim. The Court of Appeals for the Fifth District of Texas reversed the trial court’s decision in relevant part, allowing the Conference to pursue its claims.The Supreme Court of Texas held that the Conference has statutory authority to sue SMU to enforce its rights under the articles of incorporation and the Texas Business Organizations Code. The court also held that the Conference could pursue its breach-of-contract claim as a third-party beneficiary of SMU’s articles of incorporation. However, the court agreed with SMU that it was entitled to summary judgment on the false-filing claim, as the certificate of amendment did not constitute a materially false instrument.The Supreme Court of Texas affirmed the Court of Appeals’ judgment in part, allowing the declaratory judgment and breach-of-contract claims to proceed, and reversed it in part, upholding the summary judgment on the false-filing claim. The case was remanded to the trial court for further proceedings. View "SOUTHERN METHODIST UNIVERSITY v. SOUTH CENTRAL JURISDICTIONAL CONFERENCE OF THE UNITED METHODIST CHURCH" on Justia Law

In the oilfields of West Texas, a dispute arose over the ownership of "produced water," a byproduct of oil-and-gas production. COG Operating, LLC, a hydrocarbon lessee, claimed ownership of the produced water under its oil-and-gas leases, arguing that the right to produce oil and gas includes the right to handle and dispose of the resulting liquid waste. Cactus Water Services, LLC, a surface-estate lessee, countered that once hydrocarbons are separated, the remaining produced water belongs to the surface estate unless expressly conveyed otherwise.The trial court ruled in favor of COG, declaring that COG owns the produced water and has exclusive rights to its possession, custody, control, and disposition. The court of appeals affirmed this decision, holding that produced water is oil-and-gas waste that belongs to the mineral lessee, not groundwater that belongs to the surface estate. The court emphasized that the leases did not suggest an intent to reserve rights to oil-and-gas waste for the surface owner.The Supreme Court of Texas reviewed the case and affirmed the lower courts' decisions. The Court held that under Texas law, a conveyance of oil-and-gas rights includes the right to handle and dispose of produced water, which is considered oil-and-gas waste. The Court noted that produced water is inherently part of hydrocarbon production and must be managed by the operator. The Court rejected Cactus's argument that produced water should be treated as surface estate water, emphasizing that produced water is distinct from groundwater and is subject to specific regulatory requirements for waste disposal. The Court concluded that the leases conveyed the right to produced water to COG, and any reservation of rights to produced water by the surface owner must be expressly stated in the conveyance. View "CACTUS WATER SERVICES, LLC v. COG OPERATING, LLC" on Justia Law

A pickup truck driven by Trey Salinas lost control on an icy highway, crossed a median, and collided with an 18-wheeler driven by Shiraz Ali, resulting in the death of one child and severe injuries to three others. The plaintiffs argued that Ali's speed, although below the limit, was unsafe for the conditions and contributed to the severity of the accident.The jury in the district court found Werner Enterprises and Ali liable, attributing 70% of the responsibility to Werner employees other than Ali, 14% to Ali, and 16% to Salinas. The court awarded substantial damages to the plaintiffs. Werner and Ali appealed, challenging the sufficiency of the evidence, jury charge issues, apportionment, admission of evidence, and the award of future medical expenses. The Court of Appeals for the Fourteenth District of Texas affirmed the district court's judgment.The Supreme Court of Texas reviewed the case and concluded that Ali's negligence was not a substantial factor in causing the plaintiffs' injuries. The court held that the sole proximate cause of the accident was Salinas losing control of his vehicle and crossing the median into oncoming traffic. The court determined that Ali's presence and speed on the highway merely furnished the condition that made the injuries possible but did not proximately cause them. Consequently, the court reversed the judgment of the Court of Appeals and rendered judgment in favor of the defendants, Werner Enterprises and Shiraz Ali. View "WERNER ENTERPRISES, INC. v. BLAKE" on Justia Law

A City of Houston police officer, while responding to an armed robbery, collided with another motorist, Maria Christina Gomez. The officer, Bobby Joe Simmons, was driving in heavy rain with his emergency lights on but did not engage his siren. He did not exceed the speed limit and applied his brakes when the traffic light turned yellow, but his car slid into the intersection and collided with Gomez's vehicle. Gomez sued the City for negligence, seeking damages for her injuries.The trial court granted the City’s plea to the jurisdiction, citing the Texas Tort Claims Act’s emergency exception, which preserves immunity unless the officer acted with "conscious indifference or reckless disregard for the safety of others." The Court of Appeals for the Fourteenth District of Texas reversed this decision, finding a fact question regarding the officer's recklessness. The City then supplemented its plea with additional evidence and appealed again after the trial court denied the plea.The Supreme Court of Texas reviewed the case de novo and concluded that the evidence showed, at most, ordinary negligence rather than recklessness. The court held that Simmons’s actions, including adjusting his radio and not exceeding the speed limit, did not demonstrate a willful or wanton disregard for safety. Consequently, the court reversed the Court of Appeals' judgment and rendered judgment dismissing Gomez’s claim against the City for lack of jurisdiction, reaffirming the City’s immunity under the Texas Tort Claims Act’s emergency exception. View "City of Houston v. Gomez" on Justia Law

Cesar Posada sued Osvanis Lozada and his employer, TELS, Inc., after a collision between their tractor-trailers. Posada claimed negligence and negligence per se against Lozada and sought to hold TELS vicariously liable. Lozada's tire unexpectedly lost air, causing his truck to jackknife and block the highway, leading to Posada crashing into it. Lozada and TELS filed no-evidence motions for summary judgment, which the trial court granted.The trial court in El Paso County granted the no-evidence motions for summary judgment filed by Lozada and TELS, dismissing Posada's claims. Posada's motions for a new trial were denied. The Court of Appeals for the Eighth District of Texas reversed the trial court's decision, holding that a reasonable jury could find that Lozada breached his duty of care and that his actions were the proximate cause of the collision. The court of appeals also reversed the summary judgment in favor of TELS, as their liability was predicated on Lozada's liability.The Supreme Court of Texas reviewed the case and concluded that Posada failed to produce summary-judgment evidence raising a genuine issue of material fact regarding whether Lozada breached his duty of care. The court noted that the evidence showed Lozada was driving under the speed limit when his tire rapidly lost air, causing the accident. There was no evidence Lozada acted negligently in response to the tire failure. Consequently, the Supreme Court of Texas reversed the court of appeals' judgment and reinstated the trial court's judgment, dismissing Posada's claims against Lozada and TELS with prejudice. View "Lozada v. Posada" on Justia Law

Johari Powell suffered serious injuries when her 2009 Hyundai Elantra stalled in traffic and was rear-ended. Powell alleged that the car stalled due to a fuel pump failure. Paul Swacina, on behalf of Powell and her minor children, sued multiple defendants in Texas state court, including Hyundam Industrial Company, Ltd., the manufacturer of the fuel pump. Hyundam, a South Korean company, filed a special appearance under Texas Rule of Civil Procedure 120a, requesting dismissal for lack of personal jurisdiction. Hyundam argued it had no business operations or direct sales in Texas and no control over where its products were sold.The trial court overruled Swacina’s objections to an affidavit by Hyundam’s Managing Director and denied Hyundam’s special appearance. The court of appeals affirmed, holding that Hyundam purposefully availed itself of the Texas market by designing fuel pumps for the North American region, which includes Texas. The court of appeals found that Hyundam’s actions were sufficient to establish personal jurisdiction in Texas.The Supreme Court of Texas reviewed the case and reversed the court of appeals' decision. The court held that there was no evidence Hyundam specifically targeted Texas. Designing a product for the North American region, which includes Texas, does not constitute purposeful availment of the Texas market. The court emphasized that mere foreseeability of a product ending up in Texas is insufficient for personal jurisdiction. The court concluded that Hyundam did not engage in any conduct specifically targeting Texas and thus did not purposefully avail itself of the Texas market. The Supreme Court of Texas rendered judgment dismissing the case against Hyundam. View "Hyundam Industrial Co. Ltd. v. Swacina" on Justia Law

A Piper Light Sport Aircraft lost engine power and crashed on a runway in Addison, Texas, causing severe injuries to Sheema Shaik, a passenger, and emotional distress to her husband, Touseef Siddiqui. The Shaiks, Texas residents, filed a lawsuit in Dallas County against multiple parties, including BRP-Rotax GmbH & Co. KG (Rotax), the Austrian manufacturer of the aircraft engine. They claimed that Texas courts had specific personal jurisdiction over Rotax because it intentionally placed the defective engine into the stream of commerce, leading to its arrival in Texas.The trial court denied Rotax's special appearance motion to dismiss for lack of personal jurisdiction. The Court of Appeals for the Fifth District of Texas affirmed this decision, concluding that Rotax purposefully availed itself of the Texas market under the "stream-of-commerce-plus" test. The court of appeals cited Rotax's distribution agreement with Kodiak, its website, a repair center in Texas, and the number of Rotax engines registered in Texas as evidence of purposeful availment.The Supreme Court of Texas reviewed the case and reversed the lower court's decision. The court held that Rotax did not purposefully avail itself of the Texas market. The evidence showed that Rotax's engines reached Texas through the unilateral actions of third parties, not through any direct targeting or control by Rotax. The court emphasized that mere foreseeability of a product ending up in Texas is insufficient for establishing specific personal jurisdiction. Therefore, the case against Rotax was dismissed for lack of personal jurisdiction. View "BRP-Rotax GmbH & Co. KG v. Shaik" on Justia Law

Hannah and Manish Mehta married in 2000 and had triplets in 2007. Hannah became the primary caregiver, especially for one child with significant medical needs. Manish filed for divorce in 2019. The trial court granted Hannah exclusive use of the marital home and ordered Manish to pay child support and temporary spousal support. Hannah later secured a paid position with a nonprofit. During the divorce proceedings, Manish expressed concerns about Hannah's ability to maintain the home financially. The trial court's final decree included child support and spousal maintenance for Hannah.The trial court appointed Hannah and Manish as joint managing conservators, with Hannah having the right to designate the children's primary residence. Manish was ordered to pay $2,760 per month in child support and $2,000 per month in spousal maintenance for thirty-six months. Manish requested findings of fact and conclusions of law, challenging the spousal maintenance award. The trial court did not provide additional findings, and Manish appealed. The Court of Appeals for the Second District of Texas affirmed the property division but reversed the spousal maintenance award, citing insufficient evidence that Hannah would lack sufficient property to meet her minimum reasonable needs.The Supreme Court of Texas reviewed the case and held that the Court of Appeals erred in reversing the spousal maintenance award. The Supreme Court emphasized that while detailed financial evidence is ideal, courts should not disregard competent qualitative evidence. The court also noted that child-related expenses must be considered when assessing whether a spouse will have sufficient property post-divorce. The Supreme Court found legally sufficient evidence to support the trial court's award of spousal maintenance, including Hannah's role as the primary caregiver for a medically fragile child. The Supreme Court reversed the Court of Appeals' judgment in part and reinstated the trial court's spousal maintenance award. View "Mehta v. Mehta" on Justia Law