In this divorce proceeding, the Supreme Court of Texas was asked to consider whether a judgment was rendered through an email sent only to the parties' legal counsel. The case involved Eve Lynn Baker and Terry Lee Bizzle, who after nearly 20 years of marriage, filed cross-petitions for divorce. The trial court informed the parties that a same-day ruling would not be possible and that the court would "e-mail the parties with the decision" at the end of the following week.Subsequently, the trial court sent an email to the parties' attorneys outlining the allocation of assets. The court did not copy the court clerk on this email or otherwise submit it to the clerk for filing or entry in the record. The trial court later signed a modified version of Wife's proposed final decree, declaring the parties divorced on insupportability grounds and dividing the marital estate.However, the court of appeals reversed this decision, ruling that the postmortem divorce decree was void for want of subject-matter jurisdiction because the trial court had not rendered judgment completely resolving the divorce action before the wife passed away.The Supreme Court of Texas affirmed the court of appeals' decision, finding that the trial court did not render judgment in the privately communicated October 4th email, and the wife's subsequent death divested the trial court of jurisdiction to render judgment in the postmortem final divorce decree. The court held that public pronouncement of the trial court's decision is not a mere formalism but an official judicial action affording the decision legal significance. View "BAKER v. BIZZLE" on Justia Law

In this case, Bay, Ltd., a construction company, filed suit against The Most Reverend Wm. Michael Mulvey, Bishop of the Diocese of Corpus Christi, seeking to recover the value of unauthorized improvements made to a ranch leased from the Bishop by Michael Mendietta, a former Bay employee. Mendietta had used Bay's resources for these improvements without the company's consent. Bay also filed a separate lawsuit against Mendietta for damages related to his unauthorized actions, including the improvements to the ranch.Six years later, Bay and Mendietta entered into an agreement settling their claims. This agreement required Mendietta to pay Bay $750 per month to avoid a $1.9 million final judgment. The agreement allocated $175,000 of the settlement amount to Mendietta's homestead, but did not allocate specific values to the other injuries suffered by Bay, including the improvements to the ranch.After Bay dropped its claims against Mendietta and proceeded to trial against the Bishop alone, the jury awarded damages to Bay. However, the Bishop requested a settlement credit of $1.725 million (the total settlement amount minus the $175,000 allocated to Mendietta's homestead). The lower court denied this request, but the appellate court reversed, concluding that the unallocated amount of the settlement exceeded the jury's award to Bay.The Supreme Court of Texas affirmed the appellate court's decision, holding that the agreement between Bay and Mendietta constituted a $1.9 million settlement agreement. Because the agreement allocated $175,000 to an injury other than the one Bay sought to recover from the Bishop, the remaining $1.725 million was credited against the jury's verdict, resulting in a take-nothing judgment for Bay. View "BAY, LTD. v. MULVEY" on Justia Law

The Supreme Court of Texas examined whether a lender could rescind a loan acceleration and reaccelerate the loan simultaneously, thereby resetting the foreclosure statute of limitations under the Texas Civil Practice and Remedies Code Section 16.038. The plaintiffs, Linda and Thomas Moore, defaulted on their home loan, leading to an acceleration of the loan by the lenders, Wells Fargo Bank and PHH Mortgage Corporation. The lenders subsequently issued notices rescinding the acceleration and then reaccelerating the loan. The Moores sued, arguing that the foreclosure statute of limitations had run out because the lenders' rescission notices also included notices of reacceleration. The federal district court ruled against the Moores, leading to their appeal and the subsequent certification of questions to the Supreme Court of Texas by the Fifth Circuit. The key question was whether simultaneous rescission and reacceleration could reset the limitations period under Section 16.038.The Supreme Court of Texas held that a rescission that complies with the statute resets the limitations period, even if it is combined with a notice of reacceleration. The court reasoned that the statute doesn't require the rescission notice to be separate from other notices, nor does it impose a waiting period between rescission and reacceleration. The court's ruling means that lenders can rescind and reaccelerate a loan simultaneously, thereby resetting the foreclosure statute of limitations. View "MOORE v. WELLS FARGO BANK, N.A." on Justia Law

Cobalt International Energy partnered with three Angolan companies to explore and produce oil and gas off the coast of West Africa. Later, the federal Securities and Exchange Commission announced it was investigating Cobalt for allegations of illegal payments to Angolan government officials and misrepresentation of the oil content of two of its exploratory wells. This led to a significant drop in Cobalt’s stock price and prompted a class action lawsuit from Cobalt's investors, led by GAMCO, a collection of investment funds that held Cobalt shares. Prior to these events, Cobalt had purchased multiple layers of liability insurance from a number of insurance companies, collectively referred to as the Insurers in this case. When the allegations surfaced, Cobalt notified the Insurers, who denied coverage on the grounds that Cobalt's notice was untimely and certain policy provisions excluded the claims from coverage.In 2017, Cobalt filed for bankruptcy and began settlement negotiations with GAMCO. Eventually, a settlement agreement was reached, which stipulated that Cobalt would pay a settlement amount of $220 million to GAMCO, but only from any insurance proceeds that might be recovered. Cobalt and GAMCO then jointly sought approval of the settlement from the federal court and the bankruptcy court, both of which granted approval.The Insurers then filed a petition for a writ of mandamus, arguing that the settlement agreement was not binding or admissible in the coverage litigation, that Cobalt had not suffered a "loss" under the policies, and that GAMCO could not sue the Insurers directly.The Supreme Court of Texas held that (1) Cobalt had suffered a “loss” under the policies because it was legally obligated to pay any recoverable insurance benefits to GAMCO, (2) GAMCO could assert claims directly against the Insurers, and (3) the settlement agreement was not binding or admissible in the coverage litigation to establish coverage or the amount of Cobalt’s loss. The court reasoned that the settlement was not the result of a "fully adversarial proceeding," as Cobalt bore no actual risk of liability for the damages agreed upon in the settlement. The court conditionally granted the Insurers' petition for a writ of mandamus in part, ordering the trial court to vacate its previous orders to the extent they relied on the holding that the settlement agreement was admissible and binding to establish coverage under the policies and the amount of any covered loss. View "IN RE ILLINOIS NATIONAL INSURANCE COMPANY" on Justia Law

In a dispute between Sealy Emergency Room, L.L.C., Dr. Kannappan Krishnaswamy, and Free Standing Emergency Room Managers of America, L.L.C. (FERMA), along with its doctors, the Supreme Court of Texas ruled on two issues regarding the finality and appealability of judgments. The case arose from a contractual dispute between Sealy ER and FERMA, with both parties filing various claims and counterclaims against each other. The trial court granted FERMA's motion for partial summary judgment, dismissing all of Sealy ER's claims, and later granted FERMA's motion to sever these claims into a separate action.The Supreme Court held that when claims are severed into separate actions, the test for finality applies to each action separately. Thus, any claims that remain pending in the original action are not relevant in deciding whether there is a final judgment in the severed action. Procedural errors in ordering a severance do not affect the finality of the judgment or appellate jurisdiction.Secondly, the court held that when a party seeks attorney’s fees as a remedy for a claim under a prevailing-party standard, a summary judgment against the party on that claim also disposes of its fee request. Therefore, the court’s failure to specifically deny the fee request will not prevent finality if the court’s orders in fact dispose of all parties and claims.In this case, the court concluded that the trial court’s order granting partial summary judgment disposed of all parties and claims that were later severed into a new action. As a result, the severed action became final when the severance order was signed, and Sealy ER timely appealed. The court of appeals erred in holding that it lacked appellate jurisdiction, so the Supreme Court reversed and remanded for the court of appeals to address the merits of the appeal. View "SEALY EMERGENCY ROOM, L.L.C. v. FREE STANDING EMERGENCY ROOM MANAGERS OF AMERICA, L.L.C." on Justia Law

The case involves a fatal accident that occurred at a private railroad crossing owned by Ezra Alderman Ranches, Inc. and operated by Union Pacific Railroad Company. Rolando Prado, Jr. died when his vehicle was struck by a Union Pacific train at the crossing. His family members (the Prados) sued both Union Pacific and Ezra Alderman Ranches, Inc. for negligence. The central issue before the Supreme Court of Texas was whether the evidence was sufficient to create a fact issue on whether the railroad crossing, which was protected by both a stop sign and a crossbuck sign, was "extra-hazardous" and whether the landowner knew it was "unreasonably dangerous."The court held that the evidence was insufficient to support a finding that the crossing was extra-hazardous. The court reasoned that the crossing had a stop sign in addition to the usual crossbuck sign, and anyone who actually stopped at the sign could clearly see a train coming from either direction. The expert testimony that suggested drivers would not stop at a particular stop sign because it "lacks credibility" did not establish that all reasonably prudent drivers would not, much less could not, stop at the sign.The court also held that there was no evidence to support a finding that the landowner, Ezra Alderman Ranches, Inc., had actual knowledge that the crossing was unreasonably dangerous. The court determined that the evidence indicated that the landowner knew of the high volume of traffic at the crossing, but it did not establish that the landowner had actual knowledge that the crossing was unreasonably dangerous.The court reversed the decision of the court of appeals and reinstated the judgment of the trial court in favor of Union Pacific and Ezra Alderman Ranches, Inc. View "UNION PACIFIC RAILROAD COMPANY v. PRADO" on Justia Law

The case in question was heard by the Supreme Court of Texas and revolved around the interpretation of the term "psychiatrist" as it applies to the involuntary civil commitment of individuals exhibiting signs of mental illness. The case involved a 34-year-old man, A.R.C., who had exhibited psychotic symptoms and delusional behavior. Two second-year psychiatry residents completed the required "certificates of medical examination for mental illness," as outlined in Tex. Health & Safety Code § 574.009(a). However, a question arose as to whether these residents could be considered psychiatrists under the statute.The Supreme Court of Texas ruled that these residents were indeed psychiatrists, reversing the lower court's judgment. The court determined that the residents, who were licensed under a physician-in-training program and were engaged in specialized psychiatric training, fell within the definition of a physician specializing in psychiatry. The court rejected the argument that only board-certified psychiatrists qualify under the statute, stating that physicians who specialize in psychiatry qualify as psychiatrists under § 574.009(a).The court emphasized that it is the judge, not the physician, who ultimately decides whether involuntary commitment is necessary or lawful. The court also noted that the legislature has the power to amend the qualifications for psychiatrists and other physicians as it sees fit, provided it adheres to the constitutional requirement of competent medical or psychiatric testimony.The Supreme Court of Texas remanded the case to the court of appeals for consideration of A.R.C.'s remaining challenges. View "IN RE A.R.C." on Justia Law

This case involves a dispute over the right to use a gravel crossing over a railroad track in Johnson County, Texas. The landowners, Nathan Albert and Chisholm Trail Redi-Mix, LLC, were granted an easement by necessity, an easement by estoppel, and a prescriptive easement by a jury, allowing them to cross the railroad tracks owned by the Fort Worth & Western Railroad Company (Western). The jury also found that the landowners did not trespass on the railroad’s property. The Court of Appeals reversed these findings, stating that the evidence was legally insufficient to support the jury’s easement findings and factually insufficient to support the trespass finding. The Supreme Court of Texas partially reversed the Court of Appeals' judgment. It held that while the evidence was legally insufficient to support the jury's findings of an easement by necessity and an easement by estoppel, it was legally sufficient to support the prescriptive easement. The Supreme Court of Texas remanded the case back to the Court of Appeals to consider unresolved issues involving the boundaries and permitted uses of the easement. The dispute started when the railroad company began sending notices to the landowners that they were trespassing on the railroad’s property by using the gravel crossing. Despite this, the gravel crossing had been used without issue for many years and had been referenced as a "private road" on local maps since the 1940s. View "ALBERT v. FORT WORTH & WESTERN RAILROAD COMPANY" on Justia Law

The Supreme Court of Texas evaluated a case in which a land development company, Bellpas, Inc., sought to detach property from one school district and annex it to another. According to the Texas Education Code, if the school boards of the affected districts disagree on the petition, the Commissioner of Education can resolve the issue in an administrative appeal. However, the Lampasas Independent School District (LISD) board neglected to approve or disapprove the petition, leading to a disagreement over whether the Commissioner of Education had jurisdiction over the administrative appeal.The Supreme Court of Texas held that the Commissioner of Education did have jurisdiction over the administrative appeal. The court reasoned that a school board "disapproves" a petition if it does not approve it within a reasonable time after a hearing, as per the plain reading of the Education Code. The court also concluded that the Commissioner did not lose jurisdiction by failing to issue a ruling within 180 days, as the statute's deadline is not jurisdictional.The case was returned to the Court of Appeals to resolve the appeal on its merits. The Supreme Court of Texas stressed that the delay in the administrative appeal process should not deprive the appellant of a decision on the merits of their petition and criticized the school board for refusing to make a decision, thus avoiding any ruling on the merits. View "MORATH v. LAMPASAS INDEPENDENT SCHOOL DISTRICT" on Justia Law

In June 2020, a local newspaper in Polk County published an article criticizing a local assistant district attorney, Tommy Coleman. The article claimed that Coleman had "assisted with the prosecution of Michael Morton" while he was a prosecutor in Williamson County. Michael Morton was wrongfully convicted in 1987 due to prosecutorial misconduct, a conviction that occurred before Coleman began practicing law. Morton was exonerated in 2011 after spending nearly 25 years in prison. The article specifically highlighted an instance during a post-conviction hearing where Coleman mocked requests for DNA testing of evidence that would eventually exonerate Morton. Coleman sued the newspaper and its author for defamation, arguing that the claim that he assisted in Morton's prosecution was false and defamatory.The Supreme Court of Texas held that the article's statement that Coleman "assisted with the prosecution of Michael Morton" was substantially true given Coleman’s public involvement in his office’s efforts to resist DNA testing of the evidence that exonerated Morton. The Court ruled that even if the article was not precise in its characterization of Coleman's role, the "gist" of the article - that Coleman supported the efforts to keep Morton behind bars by resisting DNA testing - was substantially true and therefore not actionably defamatory. As such, Coleman's claims were dismissed. View "POLK COUNTY PUBLISHING COMPANY v. COLEMAN" on Justia Law