Justia Texas Supreme Court Opinion Summaries

The case involves a dispute between a group of commercial property insurers and their insured, which owns and manages commercial properties. The dispute centers on damage to a Dallas food-distribution warehouse after a water line ruptured and caused significant property loss. The insured notified the insurers, who made some payments, but disagreements arose about the remaining scope of damage and costs. The insurance policy included an appraisal provision allowing either party to demand an appraisal if they disagreed on the “amount of loss.” The insurers invoked the appraisal process, but the insured refused, arguing that the real dispute was about coverage and not the amount of loss, and that insurers acted in bad faith.The insurers filed suit and moved to compel appraisal in the trial court, which denied their motion. The insured counterclaimed, alleging breach of contract, violations of the Insurance Code, and bad faith. The insurers sought mandamus relief in the court of appeals, which also denied their request.The Supreme Court of Texas reviewed the matter and found that the parties’ disagreement was at least partly about the amount of loss, not solely about coverage or causation. The Court held that appraisal provisions in insurance policies are generally enforceable absent illegality or waiver. The justices concluded that potential coverage disputes or alleged bad faith by the insurers do not preclude the right to appraisal. The Court held that the trial court clearly abused its discretion in denying the insurers’ motion to compel appraisal, and the insurers lacked an adequate remedy by appeal. The Supreme Court of Texas conditionally granted the petition for writ of mandamus and directed the trial court to grant the motion to compel appraisal, stating that the writ would issue only if the trial court did not comply. View "IN RE ACE AMERICAN INSURANCE COMPANY" on Justia Law

A company providing paratransit and microtransit services under contract with a regional public transportation authority subcontracted another company to supply vehicles and drivers. After several months, the subcontractor terminated the agreement and brought suit against the transportation company and the authority, asserting claims including breach of contract, quantum meruit, tortious interference, fraud, and negligent misrepresentation. The fraud claim centered on alleged false representations made to induce the subcontract.The trial court (Texas District Court) ruled on a motion to dismiss under Texas Rule of Civil Procedure 91a, which allows dismissal if pleadings show no legal or factual basis for relief. The court dismissed the fraud and other tort claims against all defendants, as well as the breach of contract claim against the transportation authority and its primary contractor. It limited potential contract damages as to the contractor’s subsidiary and severed and abated remaining claims. The subcontractor appealed the dismissal of its claims against the main transportation company.The Court of Appeals for the Fifth District of Texas reversed in part, finding that the breach of contract and fraud claims against the main transportation company had a basis in law and that its statutory immunity under Texas Transportation Code § 452.056(d) was not conclusively established. The Supreme Court of Texas, reviewing only the fraud claim, held that the statutory immunity did apply. Because the pleadings showed the transportation company was contractually performing the authority’s function, and the authority itself would be immune from a fraud claim (an intentional tort), the company was likewise immune from liability for fraud. Accordingly, the Supreme Court of Texas reversed the Court of Appeals’ judgment and reinstated the trial court’s dismissal of the fraud claim. The case was remanded for further proceedings on any remaining claims. View "MV TRANSPORTATION, INC. v. GDS TRANSPORT, LLC" on Justia Law

A group of individual taxpayers residing in Willacy County and a local school district challenged the ongoing collection of an ad valorem tax by the South Texas Independent School District (STISD). The tax was originally authorized in 1974 by a vote of Willacy County residents for a rehabilitation district serving persons with disabilities. Over time, STISD’s mission expanded, and the plaintiffs alleged that it no longer primarily serves disabled persons, which they claim deviates from the original purpose approved by voters. The individual taxpayers asserted they were directly harmed by the collection of this tax, while the local school district argued that the tax created financial disadvantages and competitive harm due to double taxation and unequal funding.The case was first heard by a trial court, which denied STISD’s plea to the jurisdiction, allowing the plaintiffs’ claims to proceed. On interlocutory appeal, the Court of Appeals for the Thirteenth District of Texas reversed, holding that both the taxpayers and the local school district lacked standing. The appellate court reasoned that the taxpayers’ claims, if allowed, risked significant disruption of government operations and did not meet the requirements for taxpayer standing. It also found that the school district failed to allege a concrete or particularized injury.The Supreme Court of Texas reviewed the case and determined that the appellate court erred in dismissing the individual taxpayers’ claims for lack of standing. The Supreme Court held that the individual taxpayers had standing under the traditional constitutional test because they alleged a particularized, personal financial injury traceable to STISD’s actions, and their requested relief would redress that injury. However, the Court affirmed the dismissal of the local school district’s claims, finding its alleged injuries too speculative and not directly traceable to STISD. The case was remanded to the appellate court to consider other unresolved jurisdictional issues. View "BUSSE v. SOUTH TEXAS INDEPENDENT SCHOOL DISTRICT" on Justia Law

The case centers on an economic development agreement between a city and county in Texas and a private foundation, aimed at fostering the construction of a retail shopping center anchored by a Gander Mountain store. The city and county pledged portions of future sales-tax revenues to the foundation, which used the funds to secure a construction loan for the facility. The agreements required that the tax proceeds be used solely to repay the construction debt. Gander Mountain operated for eleven years before closing its store, but the shopping center continued to generate significant economic activity and tax revenue, with the former anchor tenant’s space later occupied by another retailer.After Gander Mountain’s closure in 2015, the city and county ceased payments, claiming the public purpose of the grants had ended. They sought declaratory relief in the District Court of Navarro County, arguing that continued payments would be unconstitutional under the Texas Constitution’s Gift Clauses. The district court granted summary judgment to the city and county, ruling that the closure ended the public purpose and that the agreements lacked sufficient controls to ensure public purposes were met. The Court of Appeals for the Tenth District of Texas affirmed, holding that the economic development grants remained subject to the Gift Clauses and that the agreements failed to satisfy their requirements.The Supreme Court of Texas reviewed the case and held that economic-development grants authorized by article III, section 52-a of the Texas Constitution remain subject to the Gift Clauses. The Court determined that the lower courts erred by focusing narrowly on the operation of a specific store rather than the broader public purpose of economic development. It held that the agreements likely satisfied the constitutional requirements of public purpose, consideration, and adequate controls, and that summary judgment was improper. The Supreme Court of Texas reversed the lower courts’ judgments and remanded the case for further proceedings. View "JPMORGAN CHASE BANK, N.A. v. CITY OF CORSICANA AND NAVARRO COUNTY" on Justia Law

RJR Vapor, a company selling oral nicotine products in Texas, including VELO nicotine pouches, sought a tax refund after paying the Texas Cigars and Tobacco Products Tax under protest. VELO pouches consist of a porous material filled with a dry mixture of microcrystalline cellulose (a plant-based substance) and nicotine isolate, along with flavorings and preservatives. Unlike traditional tobacco pouches, which use ground tobacco leaf, VELO uses non-tobacco plant matter combined with nicotine extracted from tobacco leaves. The key legal question was whether these pouches qualify as “tobacco products” under Texas Tax Code, specifically as products “made of tobacco or a tobacco substitute.”After RJR paid the tax and filed suit, the trial court ruled in RJR’s favor, finding that VELO pouches are not taxable tobacco products and granting a refund. The trial court also found the statutory phrase “made of tobacco or a tobacco substitute” unconstitutional, both facially and as applied. The Court of Appeals for the Third District of Texas affirmed, agreeing that VELO pouches are neither “made of tobacco” nor “made of . . . a tobacco substitute,” and declined to reach RJR’s constitutional challenges, considering them moot because the products were not taxable.The Supreme Court of Texas reviewed the case and reversed the decision of the court of appeals. The Supreme Court held that VELO pouches are “made of . . . a tobacco substitute” because their primary ingredients—plant matter and nicotine—take the place and function of tobacco in products expressly taxed by the statute, such as snus or moist snuff. The Court rendered judgment that VELO pouches are taxable tobacco products under Texas law and remanded the case to the court of appeals to consider RJR’s equal-and-uniform constitutional challenge to the tax. View "HANCOCK v. RJR VAPOR CO., LLC" on Justia Law

The case concerns a dispute between two drivers following a car accident in a parking lot. The plaintiff sought to recover medical expenses for injuries allegedly sustained in the collision. To establish the reasonableness and necessity of her medical costs, the plaintiff submitted affidavits from her medical providers under Section 18.001 of the Texas Civil Practice and Remedies Code. The defendant responded by serving counteraffidavits from qualified experts, challenging only portions of the claimed medical expenses—not the entirety of each provider’s charges. In response, the plaintiff designated the defense experts as her own, intending to rely on their affidavits regarding uncontested medical charges.The trial court, sitting in Collin County, sustained the defendant’s objections and excluded all affidavits from the two contested providers, reasoning that any counteraffidavit required all costs from that provider to be supported by expert testimony at trial. The plaintiff’s attempt to admit the counteraffidavits themselves was also denied on hearsay grounds. The jury awarded only the uncontested medical costs from the third provider. The Court of Appeals for the Fifth District of Texas affirmed, holding that a compliant counteraffidavit rendered the plaintiff’s Section 18.001 affidavits insufficient, thereby requiring expert testimony for all costs from providers whose affidavits were challenged, even in part.The Supreme Court of Texas reversed the court of appeals’ judgment. It held that when a counteraffidavit challenges only part of a medical-cost affidavit, the uncontested portions of the affidavit remain competent evidence under Section 18.001 and may be submitted to the jury. Furthermore, the court held that counteraffidavits can also be admissible for the uncontested claims they affirm. The court remanded the case to the trial court for further proceedings consistent with this holding. View "ORTIZ v. NELAPATLA" on Justia Law

A group of businesses and consumers involved in the sale and manufacture of consumable hemp products containing manufactured delta-8 THC challenged actions taken by the Texas Department of State Health Services and its commissioner. Following federal and state legislative changes in 2018 and 2019 that removed “hemp” and certain tetrahydrocannabinols (THC) in hemp from the definition of controlled substances, the Texas commissioner objected to a federal rule that would have further decontrolled hemp-derived extracts, including delta-8 THC. The commissioner then amended the state schedules to clarify that manufactured delta-8 THC remained a Schedule I controlled substance, leading to substantial business disruption for the vendors who had entered the delta-8 market.The vendors sued in district court, arguing that the commissioner exceeded her authority both procedurally and substantively under Texas law by modifying the schedules in a way that contradicted the Texas Farm Bill, and that the Department’s website statement about delta-8 THC was an invalid rule under the Texas Administrative Procedure Act (APA). The trial court denied the Department’s plea to the jurisdiction (challenging standing and sovereign immunity) and issued a temporary injunction against enforcement of the amended schedules and the website statement. The Court of Appeals for the Third District of Texas affirmed, concluding that the vendors had standing, the claims were justiciable, and a temporary injunction was appropriate.The Supreme Court of Texas held that the vendors had standing and their claims were ripe for review. However, it concluded that the commissioner acted within her broad statutory discretion and followed proper procedures under Health & Safety Code § 481.034(g) in objecting to the federal rule and amending the schedules. The court also held that the website statement was not an APA “rule.” Accordingly, it reversed the injunction and rendered judgment for the Department, with the only affirmed portion being the finding of standing. View "TEXAS DEPARTMENT OF STATE HEALTH SERVICES v. SKY MARKETING CORP." on Justia Law

A helicopter manufactured in 1997 by Bell Helicopter Textron Inc. was involved in a fatal crash in 2017 after an engine cowling came loose and struck the tail rotor. The pilot, working for a later owner, died in the accident. The pilot’s family brought suit against Bell, alleging that the flight manual was defective for failing to include an explicit warning about the dangers of flying with an unsecured engine cowling, even though the manual included a checklist item stating the cowling should be “Secured.” The physical cowling and its fasteners were original to the aircraft and had not been replaced or modified.Bell asserted that the General Aviation Revitalization Act of 1994 (GARA), an 18-year statute of repose, barred the suit. The plaintiffs responded that the repose period had been reset because Bell periodically revised the flight manual in the years before the crash. The 270th District Court of Harris County denied Bell’s summary judgment motion without explanation. Bell then sought mandamus relief from the Fourteenth Court of Appeals, which denied the petition without a substantive opinion.The Supreme Court of Texas held that GARA’s 18-year clock is only reset when a “new” part or component, including a substantive revision to the flight manual, is added or replaced and is alleged to have caused the accident. Because the engine-cowling instruction in the manual, which was the alleged defect, had not been revised since 1997, and no relevant “new” part was implicated, the rolling provision of GARA did not apply. The court conditionally granted Bell’s petition for writ of mandamus and directed the district court to grant summary judgment for Bell, holding that GARA bars the suit and that mandamus relief was appropriate to prevent litigation Congress has expressly foreclosed. View "IN RE BELL HELICOPTER SERVICES INC." on Justia Law

Two former school-board members of the Webb Consolidated Independent School District requested information from the district related to agenda items for an upcoming board meeting. When the district failed to provide this information, the board members sued the district under Texas Education Code Section 11.1512, seeking injunctive relief and attorney’s fees. The trial court granted a temporary injunction ordering the district to turn over specific documents. The district did not appeal this order. Before the case could proceed to trial, both members’ terms expired.Following the injunction, the plaintiffs amended their claims to address additional document requests and participated in a related administrative proceeding concerning their censure by the board. The Texas Commissioner of Education dismissed one of their claims for lack of jurisdiction. The district then moved to dismiss the lawsuit, arguing that the board members were no longer entitled to the information, that the members failed to exhaust administrative remedies, and that some claims were moot. The trial court denied the district’s motions, and the district appealed. The Court of Appeals for the Fourth District of Texas found that the claims for information were moot but held that the request for attorney’s fees remained live because the board members had obtained a temporary injunction.The Supreme Court of Texas reviewed the case and held that, in this specific statutory scheme, obtaining an injunction under Section 11.1512 ordering the district to produce information conferred prevailing-party status on the board members, entitling them to reasonable attorney’s fees for that portion of the case, even though the case was mooted before final judgment. The court also held that exhaustion of administrative remedies was not required before seeking injunctive relief under this statute. The court affirmed the court of appeals’ judgment and remanded for a determination of reasonable, recoverable attorney’s fees. View "WEBB CONSOLIDATED INDEPENDENT SCHOOL DISTRICT v. MARSHALL" on Justia Law

A business dispute arose when an employee hired to supervise construction projects for a company was found to be diverting workers, who were being paid by the company, to work on personal construction ventures organized jointly with others. This scheme was uncovered after discrepancies in worksite attendance were noticed and investigated. The company then sued the parties involved for theft of services, tortious interference, and unjust enrichment, alleging that the defendants benefited from the misappropriated labor. During the litigation, it was discovered that some potentially relevant business records and emails were unavailable, leading to further disputes about whether these materials were intentionally withheld to prevent discovery.Following a jury trial in the 68th District Court of Dallas County, the jury found in favor of the plaintiff company and awarded damages. The defendants, Copper Creek Distributors, Inc. and Escoffie, appealed to the Court of Appeals for the Fifth District of Texas. On appeal, they raised several issues, including challenges to the sufficiency and admissibility of damages evidence, liability findings, and procedural matters. However, the court of appeals only addressed the trial court’s decision to give a spoliation instruction to the jury, found it to be erroneous and harmful, and remanded for a new trial, without considering other appellate points that could warrant rendering judgment for the appellants.The Supreme Court of Texas reviewed the case and held that appellate courts must address issues that could require rendition before remanding for a new trial. The court concluded that the court of appeals erred by not first considering other grounds that might have fully resolved the case. The Supreme Court also found the harm analysis regarding the spoliation instruction inadequate. Therefore, it reversed the court of appeals’ judgment and remanded the case for further proceedings consistent with its opinion. View "VALK v. COPPER CREEK DISTRIBUTORS, INC." on Justia Law