The case revolves around a sexual harassment claim brought by Nicole Harris against her former employer, Fossil Group, Inc. Harris alleged that she was sexually harassed by an assistant store manager, Leland Brown, during her employment at a Fossil store in Frisco, Texas. The harassment primarily occurred through social media and included obscene and sexually explicit videos, photos, and messages. Harris claimed that she sent an email reporting the harassment through Fossil's anonymous reporting system in late April 2019, but received no response. She resigned from her position in early May 2019.The trial court granted Fossil's motion for summary judgment, ruling in favor of the company. The court found that there was no evidence that Fossil knew or should have known about the harassment but failed to remedy the situation. Harris appealed this decision.The Court of Appeals reversed the trial court's judgment. The appellate court held that Harris's testimony about her email was some evidence that Fossil knew or should have known about Brown's misconduct. The court also stated that Fossil took no remedial action after Harris sent the email.The Supreme Court of Texas disagreed with the Court of Appeals' decision. The court held that even if Fossil had received Harris's email, there was no evidence that its subsequent actions were not prompt and remedial. The court noted that mere days after Harris sent the email, she voluntarily resigned, and she did not identify any instances of interim harassment. The following week, the store manager reported the matter to human resources after learning about the harassment from another source. By the end of the month, Fossil had fired Brown. The court also held that Harris did not raise a fact issue that Fossil knew or should have known about the harassment before the date of the email. Therefore, the Supreme Court of Texas reversed the Court of Appeals' judgment and reinstated the trial court's judgment in favor of Fossil. View "Fossil Group, Inc. v. Harris" on Justia Law

The case revolves around a dispute between the Board of Regents of the University of Texas System and IDEXX Laboratories, Inc. over the interpretation of a patent licensing agreement. The agreement, signed in 2000, pertained to a peptide used to test for Lyme disease in dogs. The agreement stipulated different royalty rates for different types of products, depending on what tests were included. The dispute arose over the interpretation of two royalty provisions, one for 1% and the other for 2.5%, which could both be read to apply to the same sales of goods. IDEXX Laboratories had been paying the lower royalty rate, but the University argued that the higher rate should have been applied.The trial court ruled in favor of the University, concluding that the licensing agreement was clear and unambiguous and that the University was entitled to recover the unpaid royalties claimed plus accrued interest. On appeal, IDEXX Laboratories argued for the first time that the licensing agreement was ambiguous. The court of appeals agreed, concluding that both interpretations of the royalty provisions were reasonable and conflicting, and therefore the agreement was ambiguous. It reversed the trial court's decision and remanded the case.The Supreme Court of Texas disagreed with the court of appeals. It found that the royalty provisions were not ambiguous when read in the context of the licensing agreement itself and the objective circumstances in which the agreement was produced. The court concluded that the provisions were most reasonably interpreted to require royalties on IDEXX Laboratories' products at the higher rate stipulated in the agreement. The court reversed the court of appeals' judgment and remanded the case to that court for further proceedings. View "Board of Regents of the University of Texas System v. IDEXX Laboratories, Inc." on Justia Law

Roel Canales sued Pay and Save, a grocery store, for injuries he sustained after his foot got stuck in a wooden pallet used to display watermelons, causing him to fall and fracture his elbow. Canales had visited the store hundreds of times before and had purchased watermelons without incident. The wooden pallets, which have open sides to facilitate transport by forklifts and pallet jacks, are a common and necessary tool used by grocery stores to transport and display watermelons due to their size, weight, and shape.The trial court awarded Canales over $6 million in damages. The Court of Appeals for the Fourth District of Texas found the evidence legally but not factually sufficient to support the jury's findings regarding premises liability, reversed the decision, and remanded for a new trial. The court also ruled that Canales take nothing on his gross negligence claim.The Supreme Court of Texas disagreed with the Court of Appeals. It held that the evidence was legally insufficient to support both claims because the wooden pallet was not unreasonably dangerous as a matter of law. The court noted that there was no evidence of prior complaints, reports, or injuries from similar pallets, not just at Pay and Save’s 150 stores, but also at other grocery stores. The court also found no evidence of any code, law, or regulation prohibiting or restricting the use of wooden pallets. The court concluded that the wooden pallet was a common condition, a type of hazard that people encounter and avoid every day by exercising common sense, prudence, and caution. The court reversed the Court of Appeals' judgment in part and rendered judgment for Pay and Save. View "Pay and Save, Inc. v. Canales" on Justia Law

The case revolves around Pureza “Didit” Martinez, who was terminated from her position at the Texas Tech University Health Sciences Center at the age of 72. She filed a lawsuit alleging age discrimination against the Health Sciences Center, the Texas Tech University System, and the Texas Tech University System’s Board of Regents. The Texas Tech University System and the Board of Regents argued that they were not Martinez's employer and thus retained sovereign immunity.Previously, the trial court denied the plea to the jurisdiction filed by the Texas Tech University System and the Board of Regents, and the court of appeals affirmed this decision. The defendants argued that Martinez failed to plead allegations that could make them liable for age discrimination under the Labor Code, essentially denying being Martinez’s employer.The Supreme Court of Texas disagreed with the lower courts' decisions. The court found that Martinez's petition did not allege facts demonstrating that the Texas Tech University System or the Board of Regents employed Martinez directly or that either one controlled access to and interfered with her employment. Therefore, the court concluded that Martinez failed to allege a waiver of sovereign immunity, and the plea to the jurisdiction of the Texas Tech University System and the Board of Regents should have been granted. However, the court remanded the case to the trial court to give Martinez an opportunity to replead, as her petition did not foreclose a valid claim against those defendants. View "Texas Tech University System v. Martinez" on Justia Law

The case revolves around a dispute over the use of a property in the River Plantation subdivision, which has been operated as a golf course since the subdivision's establishment. The River Plantation Community Improvement Association (the Association) sought a declaratory judgment that the golf course property is encumbered by an implied reciprocal negative easement restricting it to use solely as a golf course. The owners of the golf course property, River Plantation Properties, LLC and Preisler Golf Properties, LLC, counterclaimed for a declaration that the property is not so encumbered.The trial court granted summary judgment for the golf course property’s owners, holding it is not burdened by an implied reciprocal negative easement as a matter of law. The court of appeals affirmed this decision, noting that when the subdivision was developed, the developers retained the Reserves without placing any restrictions on their use, and the recitals in the property records put prospective lot owners on notice that the Reserves were excluded from the subdivision’s uniform plan.The Supreme Court of Texas agreed with the lower courts and affirmed the court of appeals’ judgment. The court held that the doctrine of implied reciprocal negative easements does not apply in this case. The Association's complaint was not that a substantial number of lots in the River Plantation subdivision were burdened by express restrictions when originally conveyed by the developer while others were not. Instead, the Association argued that the property should be burdened by an entirely different restriction: golf course use only. The court concluded that there are no substantially uniform express restrictions on the River Plantation lots that the Association claims give rise to similar restrictions on the golf course property. Therefore, the golf course property is not burdened by an implied reciprocal negative easement. View "River Plantation Community Improvement Assn. v. River Plantation Properties, LLC" on Justia Law

The case revolves around J-W Power Company (J-W Power), a company that leases, sells, and services natural gas compressors used in oil and gas operations. The company maintains these compressors in many counties across Texas and often leases them to customers in neighboring counties. The case specifically involves the taxation of compressors maintained in Ector County that were leased to customers in Sterling and Irion Counties. J-W Power filed motions to correct the appraisal rolls under section 25.25(c) of the Tax Code, arguing that the appraisal rolls included “property that does not exist in the form or at the location described in the appraisal roll.” The Appraisal Review Boards (ARBs) in both counties denied the motions, leading to the current lawsuits.Previously, the district court granted summary judgment to the appraisal districts, arguing among other things that res judicata barred the section 25.25(c) motions because those motions involved the same subject matter as the prior Chapter 41 protests. The court of appeals affirmed this decision, holding that res judicata barred J-W Power’s section 25.25(c) motions, which raised “nearly verbatim” claims as compared to its prior Chapter 41 protests.However, the Supreme Court of Texas disagreed with the lower courts' decisions. The Supreme Court held that section 25.25(l) of the Tax Code preserved J-W Power’s right to file a section 25.25(c) motion notwithstanding its prior Chapter 41 protests. The court interpreted the phrase “regardless of whether” in section 25.25(l) to mean that a property owner can file a section 25.25(c) motion regardless of whether there was a prior Chapter 41 protest related to the value of the property. Therefore, the Supreme Court reversed the judgments of the court of appeals and remanded the cases for further proceedings. View "J-W POWER COMPANY v. IRION COUNTY APPRAISAL DISTRICT" on Justia Law

The case revolves around a products-liability claim brought by Jennifer Parks, individually and as the guardian of Samuel Gama, against Ford Motor Company. Gama suffered serious injuries when his 2001 Ford Explorer Sport rolled over. Parks alleged that the Explorer's design made it unstable and prone to rollovers, and that the design of its roof and restraint system increased the risk of injury in a crash. Ford moved for summary judgment, arguing that Parks’ suit is foreclosed by the statute of repose in Section 16.012(b) of the Texas Civil Practice and Remedies Code, which requires that a products liability action be brought within 15 years of the sale of a product.The trial court's proceedings were protracted and winding, with the court initially granting Ford’s summary-judgment motion, then vacating that order and granting Parks’ motion for new trial, then denying Ford’s renewed summary-judgment motion, then denying Ford’s motion for reconsideration of that order, before finally granting another summary-judgment motion by Ford. The evidence that Ford sold the Explorer to a dealership more than 15 years before Parks filed suit was overwhelming.On appeal, the Court of Appeals reversed the trial court's decision, holding that Ford did not conclusively establish the 'date of the sale' from which section 16.012(b)’s claimed protection ran. The court reasoned that Ford was required to establish the specific date on which the dealership paid Ford for the Explorer in full and that Ford has not done so.The Supreme Court of Texas reversed the Court of Appeals’ judgment. The court held that the timing of a sale does not turn on the date of payment, and any inconsistency in Ford’s evidence regarding the timing of the dealership’s payment to Ford for the Explorer is immaterial and not a basis for denying or reversing summary judgment. The court concluded that Ford's evidence easily meets the test of proving that the sale must have occurred outside the statutory period, and thus, Ford is entitled to summary judgment. View "FORD MOTOR COMPANY v. PARKS" on Justia Law

The case involves Yvondia Johnson, a 100% disabled U.S. Air Force veteran, who applied for a residence homestead tax exemption for her principal residence in Converse, Texas. The Bexar Appraisal District denied her application because her husband, also a 100% disabled U.S. military veteran from whom she is separated, claimed the same exemption for his principal residence in San Antonio, Texas.The trial court granted summary judgment for the appraisal district, arguing that Ms. Johnson was ineligible for the exemption because her husband claimed the same exemption on a different home they jointly owned. Ms. Johnson appealed, and the court of appeals reversed the decision, ruling in her favor.The Supreme Court of Texas affirmed the judgment of the court of appeals. The court held that the Tax Code bestows the exemption on each individual 100% disabled veteran who meets the express statutory requirements without regard to whether the veteran’s spouse also claims the exemption on a separate residence homestead. The court found that the plain text of Section 11.131(b) of the Tax Code unambiguously states that a 100% disabled veteran is entitled to a tax exemption for his or her residence homestead. The court concluded that Ms. Johnson satisfies the express, unambiguous requirements of Section 11.131(b) and therefore is entitled to the benefit of the tax exemption for 100% disabled veterans. View "BEXAR APPRAISAL DISTRICT v. JOHNSON" on Justia Law

A roofing contractor in Texas, Stonewater Roofing, Ltd. Co., filed a lawsuit against the Texas Department of Insurance and its Commissioner, Cassie Brown, seeking to invalidate Texas’s licensing and dual-capacity regulations for public insurance adjusters. Stonewater, which is not a licensed public insurance adjuster, argued that these laws violated free speech and due process rights under the First and Fourteenth Amendments of the U.S. Constitution. The trial court dismissed the case, siding with the state regulator, who argued that the laws regulated professional conduct, not speech, and that Stonewater failed to state valid void-for-vagueness claims under the Fourteenth Amendment’s Due Process Clause.The Court of Appeals for the Seventh District of Texas reversed the trial court's decision, holding that the regulations triggered First Amendment scrutiny because the business of public insurance adjusting necessarily involves speech. The court also held that Stonewater’s vagueness challenges survived because the Public Insurance Adjusters Act did not clearly proscribe Stonewater’s alleged conduct.The Supreme Court of Texas reversed the court of appeals' judgment. The court held that the challenged statutes do not regulate or restrict speech but, rather, representative capacity with a nonexpressive objective: employment to act on behalf of an insured in negotiating for or effecting the settlement of a claim. The court also held that the statutes are clear enough in proscribing Stonewater’s alleged conduct to preclude both its as-applied and facial vagueness challenges. The court concluded that Stonewater failed to state cognizable First and Fourteenth Amendment speech and vagueness claims, and therefore, the trial court properly granted the state regulator's dismissal motion. View "TEXAS DEPARTMENT OF INSURANCE v. STONEWATER ROOFING, LTD. CO" on Justia Law

The Supreme Court of Texas reviewed a case involving Samson Exploration, LLC and several families, including the Bordages, from whom Samson held oil-and-gas leases. The families sued Samson for unpaid royalties under those leases. The Bordages claimed that they were entitled to late charges on the late charges, arguing that the leases' Late Charge Provision imposed late charges on late charges, compounding them each month. Samson disagreed, asserting that the late charges were not compounded.Previously, the trial court found Samson liable for breach of contract and awarded the Bordages $12,955,919 in contract damages, based on the interpretation of the Late Charge Provision. The Bordages argued that collateral estoppel prevented the Supreme Court from deciding whether the Late Charge Provision calls for simple or compound interest because that issue was previously resolved in another case involving Samson and a different lessor, the Hooks case.The Supreme Court of Texas held that Texas law disfavors compound interest, and an agreement for interest on unpaid amounts is an agreement for simple interest absent an express, clear, and specific provision for compound interest. The court also held that Samson’s prior litigation of the issue does not collaterally estop it from asserting its claims here. The court reversed the judgment of the court of appeals and remanded the case to the trial court for further proceedings. View "SAMSON EXPLORATION, LLC v. BORDAGES" on Justia Law