Justia Texas Supreme Court Opinion Summaries

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The Supreme Court affirmed the judgment of the trial court that VIA Metropolitan Transit, a governmental entity, breached its duty to act as a "very cautious, competent, and prudent person" would act under similar circumstances to a passenger who was injured while riding a VIA bus, holding that VIA was liable for the passenger's injuries in this case. Curtis Meck was injured while riding a VIA bus. Meck sued VIA, alleging that VIA was a common carrier and thus owed a duty to exercise a high degree of care. The jury rendered a verdict in favor of Meck. The court of appeals affirmed. On appeal, VIA argued (1) the high-degree-of-care duty did not apply in this case, and even if it did, the Texas Tort Claims Act does not waive governmental immunity against suits for breach of that duty; and (2) there was no evidence showing that VIA breached the high-degree-of-care duty to Meck. The Supreme Court affirmed, holding (1) VIA is a common carrier; (2) the Tort Claims Act waived VIA's governmental immunity against Meck's claim; and (3) sufficient evidence supported the jury's finding that VIA breached that duty. View "Via Metropolitan Transit v. Meck" on Justia Law

Posted in: Personal Injury
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The Supreme Court reversed the judgment of the court of appeals reversing the order of the trial court that Petitioners pay $7,000 from a supersedeas bond over losing the underlying appeal and ordering Petitioners to pay $114,280 from the bond, holding that the court of appeals erred in calculating the amount. When Petitioners were ousted from land upon which their cattle grazed, they brought this action challenging the ouster. The trial court granted summary judgment in part for Respondents then, after a trial, rendered judgment that Petitioners take nothing. The trial court allowed Petitioners to suspend the judgment by posting a supersedeas bond, which meant Petitioners could keep their cattle on the leased land during the appeal. The trial court ruled that Respondent was entitled to $7,000 from the bond. The court of appeals reversed, concluding that Respondent should recover $114,280 from the bond, basing its calculation on the expense Petitioners would have incurred if the judgment had not been superseded. At issue was how "loss or damage" is calculated on release of a supersedeas bond under Tex. R. App. 24.2(a)(3). The Supreme Court reinstated the trial court's order, holding that the proper measure is the actual loss Respondent suffered because the judgment was superseded. View "Haedge v. Central Texas Cattlemen's Ass'n" on Justia Law

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The Supreme Court conditionally granted Father's petition for writ of mandamus, holding that when a nonparent requests conservatorship or possession of a child, the child's best interest is rooted in the presumption that the fit parent, rather than a court, makes the determination whether to allow that request. Over Father's objection, the trial court entered temporary orders naming Jason a possessory conservator of Abigail with rights to possession of the child. Jason, who was in a relationship with Abigail's mother until she died, had exercised care and control of Abigail when she resided with Mother for at least six months preceding Mother's death. Father filed a petition for writ of mandamus, arguing that the trial court's orders violated his right to parent Abigail without government intervention. The Supreme Court conditionally granted the writ and directed the trial court to vacate its temporary orders, holding (1) the presumption that fit parents act according to the best interest of their children applies when modifying an existing order that names a parent as the child's managing conservator; and (2) because no evidence demonstrated that Father was unfit to be Abigail's parent or did not act in her best interest, the trial court abused its discretion in ordering that Jason be named Abigail's possessory conservator. View "In re C.J.C." on Justia Law

Posted in: Family Law
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In this cattle-feeding dispute, the Supreme Court affirmed the judgment of the court of appeals overturning the trial court's denial of Appellees' post-judgment motion to compel arbitration, holding that a party does not forfeit its right to challenge a ruling on appeal from a final judgment simply by choosing not to pursue an interlocutory appeal of that ruling. Appellants brought this action alleging fraud, unjust enrichment, and other claims. Appellees moved to dismiss the suit and compel arbitration, arguing that the claims were subject to the agreement's arbitration clause. The trial court denied the motion, and Appellees did not challenge the court's ruling through an interlocutory appeal. After the trial court rendered judgment Appellees appealed, arguing that the trial court erred when it denied their motion to compel arbitration. The court of appeals reversed and remanded with instructions that the trial court order the parties to arbitration. The Supreme Court affirmed, holding (1) the court of appeals had jurisdiction to consider the trial court's denial of Appellees' motion to compel arbitration; and (2) on the merits, the court of appeals did not err in ordering arbitration. View "Bonsmara Natural Beef Co. v. Hart of Texas Cattle Feeders, LLC" on Justia Law

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The Supreme Court reversed the judgment of the court of appeals affirming the trial court's award of compensatory damages for Plaintiff on its defamation claim, holding that this was not a case of defamation but, rather, of business disparagement and that there was no evidence for either the award of general damages for Plaintiffs' reputation or the award of special damages connected to one of the allegedly defamatory statements. Plaintiff Valley Builders Supply, inc., sued its former business competitor, Defendant Innovative Block of South Texas, Ltd., alleging that Innovative's disparaging remarks about Valley's products contributed to its demise. Plaintiff submitted only its defamation claims to the jury, and the jury returned a verdict in Plaintiff's favor. The jury awarded general damages for Plaintiff's reputation injury and special damages for lost profits. The court of appeals affirmed. The Supreme Court reversed, holding (1) disparaging the quality or condition of a business's product or service is not, standing alone, defamation per se; (2) no evidence existed to support an award of general damages for harm to Valley's reputation; and (3) the pecuniary loss for which special damages were sought were not cognizable as defamation. View "Innovative Block of South Texas, Ltd. v. Valley Builders Supply, Inc." on Justia Law

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In this dispute over the amount that air ambulance providers may recover from workers' compensation insurers, the Supreme Court held that Texas law requiring that private insurance companies reimburse the fair and reasonable medical expenses of injured workers is not preempted by a federal law deregulating aviation and that federal law does not require Texas to mandate reimbursement of more than a fair and reasonable amount for air ambulance services. PHI Air Medical, LLC, an air ambulance provider, argued that the federal Airline Deregulation Act (ADA) preempted the Texas Workers' Compensation Act's (TWCA) fee schedules and reimbursement standards. An administrative law judge held that PHI was entitled to reimbursement under the TWCA's standards. On judicial review, the trial court declared that the ADA did not preempt the TWCA's reimbursement provisions. The court of appeals reversed. The Supreme Court reversed, holding (1) because the price of PHI's service to injured workers is not significantly affected by a reasonableness standard for third-party reimbursement of those services, the ADA does not preempt that standard; and (2) the ADA does not require that Texas compel private insurers to reimburse the full charges billed for those services. View "Texas Mutual Insurance Co. v. PHI Air Medical, LLC" on Justia Law

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The Supreme Court reversed the judgment of the court of appeals reversing the trial court's judgment and commitment order on the grounds that the trial court committed harmful error when it declined to submit an instruction explaining that a verdict for Defendant required only ten out of twelve votes, holding that the error was not harmful. The Supreme Court granted a motion for rehearing, withdrew its opinion and judgment of April 24, 2020, and substituted this opinion. At issue was whether a final verdict for a defendant declining to find that the defendant is a sexually violent predator (SVP) must be unanimous. Defendant requested an instruction explaining that an unanimous verdict was required to find that he was an SVP but that only ten out of twelve votes were required to find that he was not an SVP. The trial court declined to submit the requested instruction. The jury returned with a unanimous verdict finding that Defendant was a SVP. The court of appeals reversed, concluding that the trial court committed harmful error in declining to submit Defendant's instruction. The Supreme Court reversed, holding (1) the trial court erred when it denied Defendant's proffered jury instruction; but (2) the error was not harmful. View "In re Commitment of Jones" on Justia Law

Posted in: Criminal Law
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In this real estate dispute, the Supreme Court held that where the plain language of a special warranty deed limited the grantor's liability for failures of title to claims asserted by individuals "by, through and under" the grantor, the grantor could not be liable for breach of the covenant of seisin because the plaintiff asserted no such claim. The grantor of property, who purchased the property at a foreclosure sale, and the grantee entered into a residential sales contract, and the grantor conveyed the property by special warranty deed to the grantee. The grantee obtained title insurance from an insurer. When the validity of the foreclosure sale was challenged, the insurer assumed the grantee's defense and settled the suit. As the grantee's subrogee, the insurer sued the grantor for breach of the sales contract and breach of the implied covenant of seisin. The trial court found in favor of the insurer. The court of appeals reversed. The Supreme Court held (1) the special warranty deed barred the insurer's recovery because, regardless of whether it implied the covenant of seisin, the deed limited the grantor's liability for failures of title to claims asserted by individuals "by, through and under" the grantor; (2) because the failure of title did not arise from such a claim, the grantor was not liable for it; and (3) the merger doctrine barred the insurer's breach of contract claim. View "Chicago Title Insurance Co. v. Cochran Investments, Inc." on Justia Law

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The Supreme Court reversed the judgment of the court of appeals concluding that an insurer's payment of an appraisal award barred an insured's claims under the Texas Prompt Payment of Claims Act (TPPCA), Tex. Ins. Code chapter 542, holding that payment of an appraisal award does not extinguish TPPCA liability as a matter of law. After Insured's property sustained hail and wind damage, Insurer valued the property damage at $387. Believing the damage was undervalued, Insured sued, alleging breach of contract and extra-contractual claims. Insurer successfully moved the trial court to compel appraisal, and the appraisal award exceeded Insurer's prior estimates. Insurer paid the award and then filed a motion for summary judgment. The trial court granted the motion and rendered a take-nothing judgment. The court of appeals affirmed, concluding that, as a matter of law, Insured could not maintain his TPPCA claim because Insurer paid the appraisal award. The Supreme Court reversed, holding that the court of appeals' opinion was inconsistent with this Court's recent decisions on the issue. View "Marchbanks v. Liberty Insurance Corp." on Justia Law

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The Supreme Court reversed the judgment of the court of appeals concluding that an insurer's payment of an appraisal award barred an insured's claims under the Texas Prompt Payment of Claims Act (TPPCA), Tex. Ins. Code chapter 542, holding that payment of an appraisal award does not extinguish TPPCA liability as a matter of law. After Insured's property sustained damage from a storm, Insurer valued the property damage at $5,153. Believing the property damage was undervalued, Insured sued, alleging breach of contract and extra-contractual claims and invoking the policy's appraisal clause. Appraisers valued the damage at almost $15,000. Insurer paid the balance of the award and then filed a motion for summary judgment. The trial court granted the motion. The court of appeals affirmed, concluding that, as a matter of law, Insured could not maintain his TPPCA claim because Insurer paid the appraisal award. The Supreme Court reversed and remanded the case, holding that the court of appeals' opinion was inconsistent with this Court's recent decisions on the issue. View "Perry v. United Services Automobile Ass'n" on Justia Law