Justia Texas Supreme Court Opinion Summaries

After experiencing ongoing struggles with gender identity, a young adult sought a double mastectomy and was informed by the surgical clinic that a letter from a mental health practitioner was required to proceed. The petitioner requested this letter from her therapist, who had previously counseled her on unrelated matters. The therapist provided a letter recommending the surgery on February 22, 2021. Their therapeutic relationship ended on May 14, 2021. The petitioner underwent surgery on June 11, 2021, subsequently suffered medical complications, and later regretted the procedure. In 2023, she filed suit against the therapist and the therapist’s employer, alleging negligence and fraud in the issuance of the recommendation letter, and sought to hold the employer vicariously and directly liable.The case was first adjudicated in a Texas district court, where the respondents sought summary judgment, arguing that the petitioner’s claims were time-barred by the two-year statute of limitations for health care liability claims under Section 74.251(a) of the Texas Civil Practice and Remedies Code. The district court granted summary judgment and severed the claims, making the decision final as to the therapist and her employer. On appeal, the Court of Appeals for the Second District of Texas affirmed, holding that the statute of limitations began to run on the date the recommendation letter was provided.The Supreme Court of Texas reviewed the case and concluded that the lower courts erred in their interpretation of the statute of limitations. The Court held that, under Section 74.251(a), a claim is timely if filed within two years of the completion of the relevant health care treatment or the occurrence of the tort. Here, treatment concluded on May 14, 2021, and the alleged injury occurred on June 11, 2021, when the surgery was performed. Because the petitioner gave notice of her claims within two years of these events, her suit was not time-barred. The judgment of the court of appeals was reversed and remanded for further proceedings. View "ALDACO v. WOOD" on Justia Law

Jose Medellin, an experienced independent contractor, was hired to assist with a roofing project at an apartment complex in San Antonio. While working on the roof, Medellin, along with other workers, was responsible for stretching a rubber membrane across the roof’s surface. During this task, Medellin lost track of the roof’s edge, fell approximately thirty feet, and suffered serious injuries. He subsequently sued the general contractor, alleging both negligent activity and premises liability, arguing that the lack of adequate safety measures contributed to his fall.The case proceeded to a jury trial in a Texas district court, where the jury found JMI Contractors, LLC liable under both negligent activity and premises liability theories, awarding Medellin over $3.3 million in compensatory damages and an additional $1 million in exemplary damages. JMI appealed to the Court of Appeals for the Fourth District of Texas, which initially ordered a new trial on unrelated grounds. Upon rehearing, the court of appeals affirmed the trial court’s judgment, holding that the necessary-use exception applied to Medellin’s premises liability claim, and that JMI owed him a duty of care due to its control over jobsite safety.The Supreme Court of Texas granted JMI’s petition for review. The Supreme Court held that Medellin’s claim properly sounded in premises liability, not negligent activity, as his injury arose from a dangerous condition (an unguarded roof edge) rather than contemporaneous conduct by JMI. Crucially, the Court held that independent contractors cannot recover under premises liability for injuries caused by open and obvious dangers and that the necessary-use exception does not apply to them. Accordingly, the Supreme Court of Texas reversed the judgment of the court of appeals and rendered a take-nothing judgment in favor of JMI. View "JMI CONTRACTORS, LLC v. MEDELLIN" on Justia Law

A man was charged with several serious crimes and, at trial, was represented by attorneys from a law firm. His mother paid $300,000 in legal fees to the firm, based on representations made by his defense counsel about the services to be provided. The man was convicted of some charges and sentenced to prison. After an unsuccessful appeal, he and his mother sued the defense attorneys and their firm for professional negligence, breach of fiduciary duty, breach of contract, negligent misrepresentation, and fraud. They claimed that the attorneys had provided ineffective representation, failed to deliver on promises related to legal services and use of retainer funds, overcharged, failed to account for fees, and did not return unearned funds.The trial court dismissed all claims with prejudice under Texas Rule of Civil Procedure 91a, finding that the mother had no standing to sue because she was not a client, and that the Peeler doctrine barred all of the son’s claims because he had not been exonerated. The Court of Appeals for the Third District of Texas affirmed, holding that the mother lacked standing and that the Peeler doctrine categorically barred all of the son’s claims, including those about excessive fees and failure to account.The Supreme Court of Texas clarified that Peeler v. Hughes & Luce bars a convicted criminal defendant from suing defense counsel for legal malpractice unless exonerated, but does not categorically bar contract or fraud claims unrelated to the conviction. The court held that the mother had standing to bring claims for her own direct economic losses, such as overpayment or failure to return unearned fees, but could not bring claims based on an attorney-client relationship. The court affirmed the dismissal of some claims, reversed as to others, and remanded to the court of appeals to consider additional issues, including whether some claims are really fractured malpractice claims and statute of limitations defenses. View "CARDEN v. MINTON, BASSETT, FLORES & CARSEY, P.C." on Justia Law

The dispute involved neighboring commercial properties in Fort Worth, Texas. After a store was constructed on one property, the adjacent property began to experience flooding during rainfall, which led to silt and trash accumulation and eventually damaged the building and parking lot. The owner of the flooded property documented the issue over several years and sought remedies from the city, but received no resolution. Engineering reports concluded that the store’s drainage system caused increased groundwater and stormwater runoff onto the neighbor’s land.The owner of the flooded property sued the store owner and related parties for nuisance, trespass, negligent and intentional diversion of water, and violations of the Texas Water Code, seeking damages and permanent injunctive relief. Two groups of defendants moved for summary judgment, arguing that all claims were barred by the two-year statute of limitations. The District Court for Tarrant County granted both motions for summary judgment in separate orders, one of which explicitly stated it was final and disposed of all parties and claims. The trial court subsequently issued a clarifying order allowing for a permissive interlocutory appeal but did not clarify whether the summary judgment orders’ finality was undone.The Court of Appeals for the Second District of Texas determined that the trial court’s summary judgment was final and accepted appellate jurisdiction. It held that while the two-year statute of limitations barred claims for damages, it did not bar injunctive relief to abate a nuisance. Upon review, the Supreme Court of Texas held that appellate jurisdiction was proper because the summary judgment order was expressly final and was not undone by the subsequent clarifying order. On the merits, the Supreme Court determined that injunctive relief cannot be granted without an underlying cause of action, and that the two-year statute of limitations applies to all claims for damages and injunctions in this case. The judgment of the court of appeals was reversed, and the trial court’s judgment was reinstated. View "FAMILY DOLLAR STORES OF TEXAS, LLC v. JLMH INVESTMENTS, LLC" on Justia Law

A grocery store operated by the petitioner leased space in a shopping center owned by the respondent. As the lease’s expiration approached, the store attempted to renew but was unsuccessful in reaching terms. During negotiations, a representative of the store became suspicious that a competitor, El Rancho, might be taking over the location after hearing about a possible “big surprise” involving El Rancho. Despite these suspicions, the store did not ask the landlord if other negotiations were underway. The landlord had in fact already agreed to lease the space to the competitor, but continued to negotiate with the store. When the store eventually discovered the new lease, it was unable to secure an alternate location and ultimately ceased operations.A jury found for the store on its fraud claims, and the trial court awarded substantial damages. The trial court also found for the landlord on a counterclaim for breach of contract. On appeal, the Court of Appeals for the Fifth District of Texas reversed the trial court’s judgment in favor of the store, holding that the store’s reliance on the landlord’s representations was not justified as a matter of law because the existence of “red flags” negated justifiable reliance. The appellate court also held there was sufficient evidence to support the landlord’s counterclaim and remanded for a new judgment in the landlord’s favor.The Supreme Court of Texas granted review and affirmed the judgment of the court of appeals. The Supreme Court held that the store’s reliance on the landlord’s representations was unjustifiable as a matter of law because, despite being a sophisticated party and having reason to be suspicious, the store failed to exercise reasonable diligence by not inquiring further when it suspected the property might not be available. The case was remanded for entry of judgment favoring the landlord on its counterclaim. View "MAYA WALNUT LLC v. LY" on Justia Law

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