Justia Texas Supreme Court Opinion Summaries

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The Supreme Court reversed the judgment of the court of appeals affirming the trial court's grant of summary judgment for the current owners of certain property, holding that Elizabeth Mitchell's due process rights were violated in a 1999 suit in which the court entered a default judgment foreclosing a tax lien on Elizabeth's interest.After Elizabeth died in 2009, her heirs (Petitioners) brought suit to declare void the 1999 default judgment, alleging the judgment violated Elizabeth's constitutional right to procedural due process because Elizabeth was not properly served with notice of the underlying foreclosure suit. Respondents, the current owners of the property who purchased it at a tax sale or later acquired an interest in it, argued that the publicly recorded warranty deeds and county tax records could not be considered in this collateral attack. The trial court agreed and granted summary judgment for Respondents. The court of appeals affirmed. The Supreme Court reversed, holding (1) information available in relevant public records can be considered in a collateral attack on a judgment that alleges constitutional due process violations; and (2) Petitioners established that Elizabeth was not properly served in the 1999 suit, and therefore, the court in the tax foreclosure suit did not acquire personal jurisdiction over Elizabeth. View "Mitchell v. MAP Resources, Inc." on Justia Law

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In this dispute over a family ranch the Supreme Court affirmed in part and reversed in part the judgment of the court of appeals reversing in part the district court's rejection of Plaintiffs' claims on summary judgment, holding that Kenneth Berry's claims were properly rejected by the district court but that Chelsea Berry's claims should have been allowed to proceed.Kenneth and his daughter Chelsea filed this suit alleging that Defendants did not pay for the use of the ranch and that a lease between the parties was impermissibly long. The district court granted summary judgment for Defendants on all claims. The court of appeals affirmed the dismissal of Chelsea's claims and some of Kenneth's claims but reversed as to Kenneth on a statute of limitations issue. The Supreme Court reversed in part, holding that the district court (1) properly disposed of all of Kenneth's claims; but (2) erred in dismissing Chelsea's claims. View "Berry v. Berry" on Justia Law

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In this consolidated appeal involving unrelated respondents who were acquitted of driving while intoxicated (DWI), the Supreme Court affirmed the judgments of the lower courts, holding that the exception to expunction did not apply in this case.Both respondents sought expunction of the records relating to their arrests, and both had a previous DWI conviction from at least three years before the arrest that led to acquittal. Separate trial courts ordered expunction of each respondent's records. The court of appeals affirmed. The Supreme Court affirmed, holding that both respondents established their entitlement to expunction and that no exception applied. View "Ex parte K.T." on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed the judgment of the court of appeals reversing the judgment of the trial court against Landlord and in favor of the City of Baytown in this dispute over unpaid utility bills, holding that Landlord's challenge to the City's enforcement action failed to show the intentional taking or damage for public use necessary to establish a constitutional right to compensation.In this action, Landlord alleging that the City's withholding of utility service to collect payment resulted in the loss of a tenant and the disrepair of his property and was a taking in violation of the state or federal constitution. The trial court concluded that Landlord did not establish an intentional taking of private property for public use. The court of appeals reversed. The Supreme Court reversed, holding that the City's utility enforcement actions did not establish a regulatory taking of private property as a matter of law. View "City of Baytown v. Schrock" on Justia Law

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The Supreme Court denied a petition for writ of mandamus sought by Relators for relief from trial court orders granting Christina Broussard's motions to quash certain discovery subpoenas in this case brought by Broussard against Relators for personal injuries and economic losses following a rear-end collision, holding that the discovery requests sought relevant information.The subpoenas sought post-accident medical-billing information from Broussard's medical providers and third-party production of Broussard's pre-accident medical, education, employment, and insurance records. Relators argued that the requested discovery was relevant to the issue of damages causally attributable to the accident. The trial court quashed the discovery subpoenas. The Supreme Court denied mandamus relief without prejudice to Relators' seeking relief, if necessary, after the trial court has had an opportunity to reconsider its rulings, holding that the trial court should reconsider its orders in light of this Court's opinion in In re K&L Auto Crushers, LLC, 627 S.W.3d 239 (Tex. 2021). View "In re Central Oregon Truck Co., Inc." on Justia Law

Posted in: Personal Injury
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In this oil and gas case, the Supreme Court reversed the judgment of the court of appeals reversing the trial court's summary judgment, holding that a fact issue remained on Plaintiffs' claim for breach of the lease and that Plaintiffs' argument was not barred by res judicata but that the court of appeals erred by reversing a take-nothing summary judgment as to Plaintiffs' tort and statutory claims.At issue was the meaning and application of an express covenant to protect against drainage that appeared in a lease addendum that expressly limited the location of wells that may trigger Defendant-Lessee's obligation to protect against drainage but did not directly address the location of wells that may cause drainage. Plaintiffs-Lessors argued that the covenant allowed for separate triggering and draining wells and that Defendant breached the covenant by failing to protect against drainage from a non-triggering well. In response, Defendant argued that it had a duty to protect only against drainage from the limited class of triggering wells. The Supreme Court held (1) the addendum was ambiguous because both interpretations of the covenant were reasonable; (2) the court of appeals improperly reversed the trial court's take-nothing summary judgment on Plaintiffs' tort and statutory claims; and (3) remand was required for further proceedings on Plaintiffs' claim for breach of the lease. View "Rosetta Resources Operating, LP v. Martin" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals that the attorney-immunity defense was inapplicable to federal wiretap claims but reversed and rendered judgment for the defendant-attorney on Plaintiffs' state wiretap claims, holding that the attorney-immunity defense was inapplicable to the federal wiretap claims but did attach to the state wiretap claims.Plaintiffs brought this private party civil suit asserting that Defendant and others had violated the federal and Texas wiretap statutes by using and disclosing illegally intercepted electronic communications. Defendant moved for summary judgment, arguing that she was immune from liability as a matter of law because Plaintiffs' claims all stemmed from her role as an attorney in a modification proceeding. The trial court agreed and rendered summary judgment for Defendant. The court of appeals reversed. The Supreme Court affirmed in part and reversed in part, holding (1) Defendant was entitled to summary judgment on the state wiretapping claims; but (2) Defendant was not entitled to summary judgment on the claims under the federal wiretap statute because this Court is not convinced that federal courts would apply Texas's common-law attorney-immunity defense to that statute. View "Taylor v. Tolbert" on Justia Law

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In this medical malpractice case the Supreme Court reversed the decision of the court of appeals reversing the judgment of the trial court denying Defendants' motion to dismiss, holding that the trial court did not abuse its discretion in concluding that a timely-served expert report demonstrated a good faith effort to comply with the requirements of the Texas Medical Liability Act.Plaintiffs brought this case alleging that negligent perinatal care during labor and delivery caused their infant's brain damage and other serious health conditions. On the infant's behalf, Plaintiffs sued their treating physician and other healthcare providers and served expert reports on Defendants, including a report by Dr. James Balducci, an obstetrician. Plaintiff's treating physician filed a motion to dismiss, which the trial court denied. The court of appeals reversed and dismissed the claims against the treating physician with prejudice on the grounds that Dr. Balducci's report was insufficient to support Plaintiffs' healthcare liability claims. The Supreme Court reversed, holding that the trial court did not abuse its discretion in concluding that the expert report satisfied the "fair summary" standard in Tex. Civ. Proc. & Rem. Code 74.351(l), (r)(6). View "E.D. v Texas Health Care, PLLC" on Justia Law

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The Supreme Court reversed the decision of the court of appeals affirming in part and reversing in part the judgment of the trial court holding that the settlement agreement between the parties in this case barred the claims asserted in this suit and in an arbitration proceeding, holding that the trial court did not err.A billion-dollar break-up between two large corporations engaged in the international petroleum business resulted in numerous claims and lawsuits, which the parties finally resolved through a comprehensive settlement agreement. The trial court concluded that the settlement agreement, including its release provisions and a disclaimer of reliance, were valid and enforceable and barred the claims asserted in both this lawsuit and in the arbitration proceeding. The court of appeals reversed in part, concluding that the settlement agreement did not bar certain claims. The Supreme Court reversed and reinstated the final judgment of the trial court, holding that the parties fully and finally resolved the current claims through their comprehensive settlement agreement. View "Transcor Astra Group S.A. v. Petrobras America Inc." on Justia Law

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In this case involving a claim for wrongful imprisonment compensation under the Tim Cole Act, Tex. Civ. Proc. & Rem. Code 103.001-.154, the Supreme Court denied G.S.'s request for mandamus relief, holding that G.S. did not satisfy the Act's requirements.G.S. pleaded guilty to indecency with a child but was later granted habeas relief based on ineffective assistance of counsel. After it was discovered that G.S.'s alleged victim had fabricated the accusations and G.S. arrest and conviction were expunged, G.S. applied for wrongful imprisonment compensation under the Act. The Texas Comptroller of Public Accounts denied the application. G.S. subsequently filed his petition for writ of mandamus. The Supreme Court denied the writ, holding that G.S. did not establish his actual innocence as required by the Act, and therefore, he failed to prove his entitled to compensation under the Act. View "In re G.S." on Justia Law