Justia Texas Supreme Court Opinion Summaries

A commercial meat supplier delivered frozen meat products to a distributor over a series of transactions, each accompanied by an invoice. The distributor did not pay all of the invoices, claiming that some of the meat was spoiled, while the supplier insisted that the distributor simply failed to pay what was owed and invented the spoiled-meat justification later. The supplier sued for breach of contract and, alternatively, for quantum meruit (an equitable claim for the value of goods or services provided), seeking payment for the unpaid invoices. The distributor counterclaimed for breach of contract, alleging damages from the spoiled meat.At trial in a Texas district court, the jury was asked whether the distributor failed to comply with the agreements to pay for the meat and answered no. However, the jury found in favor of the supplier on its quantum meruit claim and awarded damages. The jury found that a reasonable attorney’s fee for the supplier’s attorneys was $0. The trial court entered judgment for the supplier on the quantum meruit claim and awarded the supplier its requested attorney’s fees, disregarding the jury’s finding. The Fourth Court of Appeals affirmed the trial court’s judgment on both quantum meruit and attorney’s fees.The Supreme Court of Texas concluded that the supplier’s provision of meat was covered by express agreements between the parties and, as a matter of law, quantum meruit recovery is barred when a valid contract governs the subject matter. Because the supplier was not entitled to recover in quantum meruit, it also could not recover attorney’s fees. The Supreme Court of Texas reversed the relevant portions of the court of appeals’ judgment and rendered a take-nothing judgment in favor of the distributor. View "CHAMPION FOOD SERVICE, INC. v. PROALAMO FOODS, L.L.C." on Justia Law

A railroad switchman suffered a severe injury while working for Rail Link, Inc., leading to the amputation of his leg. He brought a suit against Rail Link under the Federal Employers’ Liability Act (FELA), alleging negligence and gross negligence related to workplace safety policies, training, and environment. Rail Link responded by moving for summary judgment, arguing that it was not a “common carrier by railroad” as required for liability under FELA. The trial court initially denied Rail Link’s motion but later reconsidered and referred the question of Rail Link’s common-carrier status to the federal Surface Transportation Board (STB). In its petition to the STB, Rail Link sought a determination of its status under the ICC Termination Act (ICCTA), not under FELA.The First Court of Appeals in Houston denied the injured worker’s petition for mandamus relief, finding that the trial court did not clearly abuse its discretion by referring the issue to the STB. The dissent disagreed, reasoning that the STB, as a rate-setting body, lacks jurisdiction to determine common-carrier status for the purpose of FELA liability. The STB stayed its own proceedings while the mandamus petition was under review.The Supreme Court of Texas was then asked to issue a writ of mandamus. The Court held that a trial court may only refer a question to an administrative agency if there is a clear legislative grant of concurrent jurisdiction to the agency regarding the specific issue. The Court found no statutory authority granting the STB jurisdiction to determine common-carrier status under FELA. Therefore, the trial court abused its discretion by making the referral. The Supreme Court of Texas conditionally granted mandamus relief, directing the trial court to vacate its referral order. View "IN RE REED" on Justia Law

A laboratory testing services company, which participates in the Texas Medicaid program, was accused by the State and a private qui tam relator of violating Texas administrative regulations. The State alleged that the company failed to offer Medicaid the same pricing and discounts it provided to other payors, and that it made false statements, misrepresentations, and omissions about its compliance with those regulations. The State sought civil penalties under Texas’s Health Care Program Fraud Prevention Act for conduct going back more than twenty years.After a private party initiated a qui tam action in 2013, the Office of the Attorney General conducted a lengthy investigation, during which the company provided detailed disclosures about its billing practices and its interpretation of the relevant regulations. Despite this, the State continued to pay the company’s Medicaid claims without objection for seven years. In 2021, the State intervened, alleging that the company’s conduct resulted in overpayments by Medicaid.The trial court granted summary judgment for the company, holding that the State failed to prove that the alleged false statements, misrepresentations, or omissions were material to its payment decisions. The Court of Appeals for the First District of Texas reversed, holding that materiality was not required for omissions under the Act, and that fact issues remained regarding materiality.The Supreme Court of Texas reviewed the case. It held that the Act requires a showing of materiality for omissions as well as for false statements or misrepresentations. The court found no materiality in this record, given the State’s knowledge of and acquiescence to the company’s practices for years. The Supreme Court of Texas reversed the judgment of the court of appeals and reinstated the trial court’s judgment in favor of the company. View "LABORATORY CORPORATION OF AMERICA HOLDINGS v. THE STATE OF TEXAS" on Justia Law

A dentist who worked for a group of dental practices in Texas discovered what he alleged to be a scheme of fraudulent dental procedures billed to the Texas Medicaid program. After being promoted to a leadership role in 2019, he claimed to have uncovered practices where dentists were pressured to perform unnecessary fillings and bill them under specific ADA codes. The dentist filed a qui tam action under the Texas Health Care Program Fraud Prevention Act in 2021, naming the dental group, its management company, and related entities as defendants. The alleged scheme involved hiring dentists burdened by student debt and compensating them in ways that encouraged compliance with these practices.Previously, another employee had filed a similar qui tam action in Travis County in 2012, alleging a broader fraudulent scheme by the same dental group, including unnecessary procedures and improper billing. That action also involved a third-party payment processor and resulted in a large settlement with the State in 2019. The earlier action was still pending on appeal. After the dentist who filed the 2021 action died, the defendants moved to dismiss, arguing that the claim was extinguished by his death and barred by the earlier pending action, the public disclosure of fraud allegations, and the doctrine of dominant jurisdiction. The trial court denied all these motions, including substituting the deceased relator’s widow as representative, and the defendants sought mandamus relief in the Court of Appeals for the Fifteenth District of Texas, which denied their petition.The Supreme Court of Texas reviewed the petition for writ of mandamus. It held that qui tam claims under the Act survive the relator’s death because they belong to the State, not the individual relator. The Court also found that the defendants had not conclusively shown the later suit was based on the same facts as the earlier action, nor that public disclosure barred the claims. Finally, dominant jurisdiction did not require abatement. The Court denied the petition. View "IN RE TAFEL" on Justia Law

The case concerns a challenge to temporary closures of Boca Chica Beach in Cameron County, Texas, which were authorized to accommodate nearby rocket launches by SpaceX. Plaintiffs, several nonprofit organizations, alleged that the closures interfered with their members’ right to access the beach, a right protected under the Texas Constitution and the Open Beaches Act. They sought declaratory relief, claiming that the statutes permitting these closures conflicted with Article I, Section 33 of the Texas Constitution, which guarantees public access to Texas beaches.The respondents originally filed suit in district court against the Texas General Land Office, its commissioner, Cameron County, and the Texas Attorney General. The defendants responded with pleas to the jurisdiction, arguing that the plaintiffs, as private parties, lacked standing and that the governmental defendants were immune from suit because Section 33(d) of the Texas Constitution expressly states it does not create a private right of enforcement. The trial court agreed and dismissed the suit with prejudice. The Court of Appeals for the Thirteenth District of Texas reversed, holding that at least one plaintiff had standing, and concluded that it was not necessary to determine whether the plaintiffs’ constitutional claims were facially valid before deciding the question of immunity.The Supreme Court of Texas reviewed the case and held that Article I, Section 33(d) of the Texas Constitution precludes private enforcement of the public’s right of access to beaches, limiting enforcement authority to governmental actors. Because the claims were brought solely by private parties, they were deemed facially invalid, and the governmental defendants’ immunity from suit remained intact. The Supreme Court reversed the judgment of the court of appeals and reinstated the trial court’s dismissal for lack of jurisdiction. View "PAXTON v. SaveRGV" on Justia Law

A Texas city created a local government corporation to finance public improvements in a designated district. The corporation borrowed $17.4 million from a Wisconsin bond issuer, which funded the construction of improvements, with the city agreeing to purchase those improvements over time using assessments levied within the district. The financing structure involved a promissory note and other contracts, but the corporation did not submit these documents to the Texas Attorney General for required examination and approval. After a change in city leadership and financial difficulties, the city and corporation sued the bondholder and related parties, arguing that the failure to obtain Attorney General approval rendered the transaction void and that the financing arrangement violated provisions of the Public Improvement District (PID) Act.The trial court (District Court of Williamson County) granted summary judgment for the bondholder and other defendants, holding that while submission to the Attorney General was required, failure to do so did not void the transaction. The court also determined that the PID Act had not been violated, and it rejected challenges to certain evidence and to the award of attorney’s fees. The Court of Appeals for the Third District of Texas affirmed, agreeing that the note and contracts were not void and that statutory requirements regarding bond issuance did not apply to the transaction.The Supreme Court of Texas reviewed the case and affirmed the judgment of the court of appeals. The court held that failing to submit the promissory note and supporting contracts to the Attorney General removes the statutory defense of incontestability but does not render the transaction void or unenforceable. It further held that the transaction did not violate the PID Act because the relevant restrictions applied only to bonds issued by the city or its corporation, which was not the case here. The court also found no reversible error regarding evidentiary rulings or the award of attorney’s fees. View "RIVER CREEK DEVELOPMENT CORPORATION v. PRESTON HOLLOW CAPITAL, LLC" on Justia Law

The case concerns landowners whose property in Harris County, Texas, was condemned by the State for a highway project. After initially offering compensation, the State initiated condemnation proceedings, and the parties settled on a value for the property. Years later, the planned highway route was altered, leaving a portion of the condemned land unused. When the State indicated that some of the property was now considered surplus but refused to sell it back, the landowners assigned their rights to JRJ Pusok Holdings, LLC, to pursue a statutory right of repurchase under Texas law.JRJ filed suit in a Harris County civil court at law against the State of Texas and the Director of Right of Way, asserting a statutory right to repurchase the surplus property. The State responded with a plea to the jurisdiction, asserting sovereign immunity and lack of justiciability. The trial court granted the State’s plea and dismissed the case. The Court of Appeals for the Fourteenth District of Texas reversed the dismissal as to the repurchase claim, holding that the State’s sovereign immunity was waived for such claims, that the property had been acquired “through eminent domain,” and that the county court at law had jurisdiction.The Supreme Court of Texas affirmed the Court of Appeals’ decision. It held that the State is not immune from statutory repurchase claims arising under Chapter 21 of the Texas Property Code when condemned property is no longer necessary for public use. The court clarified that property acquired through a condemnation suit, even if settled before judgment, is acquired “through eminent domain.” It also held that a landowner may repurchase only the portion of property no longer necessary for public use and that county courts at law have concurrent jurisdiction over these claims. The court remanded the case for further proceedings. View "THE STATE OF TEXAS v. JRJ PUSOK HOLDINGS, LLC" on Justia Law

The case concerned the attempt by the Texas Department of Family and Protective Services to terminate a mother’s parental rights to her two children. After the Department was appointed temporary managing conservator and sought termination, the statutory one-year period for bringing the case to trial approached. The trial court and parties recognized the imminent deadline, and at a pretrial hearing, the judge expressed intent to grant an extension due to scheduling difficulties. However, no written extension order was entered before the statutory deadline, and the hearing transcript was incomplete due to technical issues. The Department did not provide a proposed extension order as requested, and the deadline passed with no formal extension rendered.Following the lapse of the deadline, the mother moved to dismiss the case for lack of jurisdiction, arguing that the court’s authority had expired by operation of law under Texas Family Code § 263.401(a). The trial court denied the motion, retained the case on its docket, and, after trial, terminated the mother’s parental rights. The Court of Appeals for the Eleventh District of Texas affirmed the trial court’s judgment on the merits, rejecting the mother’s jurisdictional argument.The Supreme Court of Texas reviewed the case and held that the trial court lost jurisdiction on the statutory automatic-dismissal date because no extension was properly rendered either in writing or orally in the presence of a court reporter before the deadline. The Court clarified that intent or discussion to grant an extension does not suffice; a formal act of rendition is required by law. The Court vacated the judgments of both the trial court and the court of appeals and dismissed the case for lack of jurisdiction. View "In re C.S." on Justia Law

Several cities challenged recent Texas legislative changes that reduced the fees cities could charge telecommunications companies for using public property alongside city streets. The cities argued that requiring them to charge less than market rates for this use amounted to an unconstitutional gift to the telecom companies, contrary to the Texas Constitution’s Gift Clauses. Seeking a judicial declaration to this effect, the cities sued the State of Texas as the sole defendant, asserting that the statutory rate reductions were unconstitutional.At the trial level, the district court partially granted the cities’ request for a declaratory judgment. The Court of Appeals for the Third District of Texas went further, largely siding with the cities and holding that the statutory reductions violated the Gift Clauses. The State then sought review by the Supreme Court of Texas.The Supreme Court of Texas determined that the lower courts lacked jurisdiction over the case because the cities had sued the wrong defendant. The court explained that in constitutional challenges to state statutes, the proper defendant must be the officer or agency with authority to enforce the challenged law, not the State of Texas in the abstract. The court noted that the cities failed to identify any such officer or agency, and there was no indication that any state official had enforced or threatened to enforce the challenged statutes against the cities. Because a judgment against the “State of Texas” would not redress the cities’ alleged injuries nor bind the telecommunications companies, the dispute lacked the concrete adversarial parties necessary for a justiciable controversy. The Supreme Court of Texas vacated the judgments of the lower courts and dismissed the case for lack of jurisdiction. View "STATE v. CITY OF MCALLEN" on Justia Law

A mother and father were involved in a child protective case concerning their four children after repeated reports of physical and emotional abuse, primarily against the eldest child, Karen. The Department of Family and Protective Services received several reports from school personnel and family members alleging that Karen suffered excessive corporal punishment, food deprivation, and emotional abuse by the mother. The Department intervened multiple times, eventually removing all four children from the parents’ care and placing them with relatives and later with fictive kin. The parents failed to cooperate with court-ordered services and, at one point, took the children out of state in violation of a court order.The case proceeded to a jury trial in the District Court, where the jury found grounds for terminating both parents’ rights under Texas Family Code § 161.001(b)(1)(D), (E), (N), and (O), based on endangerment, constructive abandonment, and failure to comply with a court-ordered plan. The jury determined that terminating the father’s parental rights was in the best interest of all children, and terminating the mother’s rights was in Karen’s best interest but not in the best interests of the other children. The trial court rendered judgment on the verdict, terminating parental rights accordingly and appointing the Department as managing conservator for the remaining children.On appeal, the Court of Appeals for the Seventh District of Texas affirmed the trial court’s decision regarding the endangerment findings and conservatorship. The Supreme Court of Texas reviewed the evidentiary sufficiency of the endangerment predicates under Paragraphs (D) and (E). The Court held that there was sufficient evidence to support termination of the mother’s rights as to Karen and affirmed the conservatorship as to the younger children. However, it found the evidence insufficient to support termination of the father’s rights under Paragraphs (D) and (E), reversed that portion, and remanded for further proceedings regarding other grounds and conservatorship. View "In re K.N." on Justia Law