The case revolves around a dispute between Harley Channelview Properties, LLC (Channelview) and Harley Marine Gulf, LLC (Harley Marine) over a property lease agreement. The original lease, signed in 2011, included a provision granting Harley Marine an option to purchase the property. In 2012, Channelview bought the property, subject to the Harley Marine lease. Over time, Channelview concluded that Harley Marine's purchase option had expired, and it invested $15 million in property improvements. However, Harley Marine believed the purchase option was still valid and attempted to buy the property in 2020. When Channelview refused to transfer the property, Harley Marine sued for breach of contract and sought specific performance.The trial court granted Harley Marine's motion for partial summary judgment on its contract claim and ordered Channelview to transfer the property title to Harley Marine within 30 days, even though the court acknowledged that its ruling was "interlocutory" and other issues remained unresolved. Channelview appealed, arguing that the trial court's order was equivalent to a temporary injunction.The court of appeals dismissed Channelview's appeal, ruling that the trial court had granted "permanent" relief, and thus the order was not a "temporary" injunction from which an appeal could be taken. Channelview then petitioned the Supreme Court of Texas for review.The Supreme Court of Texas reversed the court of appeals' decision. The court held that the trial court's order had the character and function of a temporary injunction because it required immediate action based on an interim ruling that a claim had merit and was effective during the pendency of the suit. The court noted that the order was "interlocutory," not final, and the trial court could modify it at any time until final judgment. The court remanded the case to the court of appeals for consideration of the merits of the appeal. View "HARLEY CHANNELVIEW PROPERTIES, LLC v. HARLEY MARINE GULF, LLC" on Justia Law

The Supreme Court of Texas was asked to consider whether Texas Rules of Evidence 509(e)(4) and 510(d)(5) apply to a discovery request for a minor plaintiff’s psychological treatment records. The minor, E.B., was seeking damages for mental anguish she suffered from witnessing her younger brother's death in an ATV accident. The ATV was sold by Richardson Motorsports, who requested all of E.B.’s psychological treatment records from her clinical psychologist and pediatrician. The court had to decide whether E.B.’s mental or emotional condition was part of her negligence claim for mental anguish damages or Richardson’s defense that post-accident causes contributed to E.B.’s anguish, thus making her psychological records discoverable under the privilege exceptions.The trial court denied E.B.’s motions to quash the discovery request and ordered that all of E.B.’s requested psychological records be produced to Richardson. E.B. and her mother then filed a petition for writ of mandamus in the court of appeals, which conditionally granted relief and directed the trial court to vacate its orders denying their motions to quash and requiring disclosure of the records. The court of appeals held that the records are privileged and the exceptions do not apply because E.B.’s pleadings make no more than a routine claim of mental anguish.The Supreme Court of Texas concluded that E.B.’s mental or emotional condition is part of her claim because she is relying on expert testimony about that condition to prove her mental anguish damages, and it is also part of Richardson’s defense that those damages have alternative causes. Thus, discovery of E.B.’s mental health care treatment records relevant to the claim or defense is not foreclosed by privilege. The court therefore conditionally granted mandamus relief and directed the court of appeals to withdraw its mandamus order preventing discovery. The court also noted that discovery of some records may be permitted on privilege-waiver grounds and further trial court proceedings are necessary to determine which parts of the records are not privileged under each rule. View "IN RE RICHARDSON MOTORSPORTS, LTD." on Justia Law

The case involves a dispute between Lakeside Resort JV, LLC, the owner of Margaritaville Resort Lake Conroe, and a guest, Mendez, who claimed to have sustained severe bodily injuries after stepping into a deep hole on the property. Mendez sued Lakeside for premises liability and negligence, seeking monetary relief between $200,000 and $1,000,000, along with pre-judgment and post-judgment interest, court costs, and expenses. Lakeside failed to timely answer the lawsuit due to an alleged failure by its registered agent for service of process to send a physical copy of the service and misdirect an electronic copy. Mendez then moved for a default judgment, which was granted by the district court.The district court signed a "Final Default Judgment" proposed by Mendez's counsel, which awarded Mendez damages exceeding the $1 million upper limit stated in her original petition. The judgment concluded with the language: "This Judgment finally disposes of all claims and all parties, and is not appealable." Lakeside, unaware of the suit, did not respond before or after the judgment was signed. After the time for a restricted appeal had run, Mendez requested an abstract of judgment and began execution. Lakeside, upon learning of the suit and resulting judgment, filed an answer containing a general denial, a motion to rescind abstract of judgment, and a combined motion to set aside the default judgment and for a new trial. The district court denied Lakeside’s motions, concluding that the judgment was final and that its plenary power had therefore expired.The Supreme Court of Texas held that the default judgment was not final despite being labeled as a "Final Default Judgment." The court reasoned that the judgment's assertion of non-appealability did not just prevent it from unequivocally expressing an intent to finally dispose of the case—it expressly and affirmatively undermined or contradicted any such intent. The court conditionally granted mandamus relief and directed the trial court to vacate the challenged orders that were predicated on that court’s conclusion that its prior judgment is final. View "IN RE LAKESIDE RESORT JV, LLC" on Justia Law

The case involves the City of Houston, which appealed a wrongful-death suit filed by the family of Dwayne Foreman, who was killed in a collision with a police cruiser. The police officers were responding to a suicide call at the time of the accident. The City argued that it was immune from the lawsuit because the officer was performing a discretionary duty in good faith and within the scope of his authority.The trial court denied the City's motion for summary judgment, and the City appealed. The court of appeals affirmed the trial court's decision, holding that a fact issue existed on the officer’s good faith, which precluded summary judgment.The Supreme Court of Texas disagreed with the lower courts. It held that, as a matter of law, the officer was performing a discretionary duty while acting within the scope of his authority in responding to the emergency call and was acting in good faith. The court reasoned that a reasonably prudent officer in the same or similar circumstances could have believed the actions were justified. Therefore, the court reversed the lower courts' decisions and dismissed the case. View "CITY OF HOUSTON v. SAULS" on Justia Law

The case revolves around a family dispute over the management of a trust established by Bernard and Jeannette Fenenbock. The trust was divided into three sub-trusts (Trust A, Trust B, and Trust C) to benefit their children, Glenna Fenenbock Gaddy and Mark Fenenbock. After Bernard's death, Glenna began serving as co-trustee with her mother Jeannette. Upon Jeannette's death, Glenna transferred shares from the sub-trusts to her own trust and sold them to her sons, Weston and Lane. Mark filed a lawsuit against Glenna, asserting that she had breached her duties as a trustee by transferring the shares without his approval as a co-trustee.The probate court ruled in favor of Mark, declaring that Mark is a co-trustee and that the transfer of shares to Glenna's Trust was void. The court ordered that the shares be restored to the sub-trusts. Glenna appealed this decision, and the court of appeals vacated the probate court’s order, concluding that the buyers of the shares, Weston and Lane, were “jurisdictionally indispensable parties” whose absence deprived the probate court of jurisdiction.The Supreme Court of Texas disagreed with the court of appeals, holding that the probate court had jurisdiction but erred by ordering Glenna to restore property she no longer owns or controls. The court reversed the court of appeals’ judgment vacating the probate court’s order, reversed the probate court’s order, and remanded the case to the probate court for further proceedings. The court noted that any appropriate relief must come from Glenna or Glenna’s Trust or through the ultimate distribution of the assets remaining in the Sub-Trusts. View "IN THE MATTER OF TRUST A AND TRUST C. ESTABLISHED UNDER THE BERNARD L. AND JEANNETTE FENENBOCK LIVING TRUST AGREEMENT" on Justia Law

Christine John and Christopher Lewis were injured in a rear-end collision involving a tractor-trailer driven by Roberto Alonzo. In the subsequent personal-injury lawsuit, Alonzo and his employer, New Prime, Inc., admitted liability for Alonzo’s negligence, leaving damages as the only issue at trial. The jury awarded $12 million to John and $450,000 to Lewis for physical pain and mental anguish. Alonzo and New Prime sought a new trial, arguing that the plaintiffs’ counsel had inflamed the jury with an unprovoked accusation of race and gender bias. The trial court rejected this motion, and the court of appeals affirmed the judgment.The Supreme Court of Texas reversed the lower courts' decisions, finding that the plaintiffs’ counsel had indeed crossed the line with an uninvited accusation of discriminatory animus. The court noted that while it is not inherently improper to question potential jurors about bias, the plaintiffs’ counsel had gone further by accusing the defense of seeking a lower damages amount because John is a black woman. The court found this argument to be inflammatory, uninvited, and unprovoked, and it concluded that it was so prejudicial that its harmfulness was incurable. The court therefore reversed the judgment and remanded the case for a new trial. View "Alonzo v. Lewis" on Justia Law

A mother sued her doctor and his medical practice for allegedly failing to perform a sterilization procedure she paid for and then failing to tell her that the procedure was not performed. She claims the doctor’s actions caused an unplanned pregnancy and the birth of her healthy fourth child. The mother sought to recover damages for medical expenses, physical pain and suffering, mental anguish, and the costs to maintain, support, and educate her daughter.The trial court granted summary judgment for the doctor as to all claims, and the mother timely appealed. A divided court of appeals reversed in part and remanded to the trial court for further proceedings. The majority affirmed the grant of summary judgment as to most of the mother’s claims, reasoning that they were impermissibly recast health care liability claims. But the majority reversed the grant of summary judgment as to the medical-negligence claim, holding that the mother had produced some evidence of duty, breach, and damages.The Supreme Court of Texas held that when a mother alleges that medical negligence proximately caused an unplanned pregnancy, that claim is not foreclosed merely because the ultimate result is the birth of a healthy child. But the recoverable damages are limited. The mother may recover the cost of the sterilization procedure and economic damages designed to compensate for injuries proximately caused by the negligence, such as medical expenses incurred during the pregnancy, delivery, and postnatal period, if proven. But Texas law does not permit recovery of the expenses of raising the healthy child, or any noneconomic damages, because the birth and life of a healthy child do not constitute an injury under Texas law. The court reversed the court of appeals’ judgment in part and reinstated the trial court’s judgment. View "Noe v. Velasco" on Justia Law

The case involves two plaintiffs, Michael Grim and Jim Maynard, who were employees of the Denton Municipal Electric (DME), a local electric utility owned by the City of Denton. The plaintiffs supported the construction of a controversial new power plant, the Denton Energy Center (DEC). Keely Briggs, a member of the Denton city council, opposed the new plant and leaked internal city documents about the project to a local newspaper. The plaintiffs reported Briggs's leak of confidential vendor information, alleging it violated the Public Information Act and the Open Meetings Act. They claimed that this report triggered the protections of the Whistleblower Act. The plaintiffs were later fired, which they alleged was retaliation for their report about Briggs.The case was initially heard in the district court, where the city argued that the Whistleblower Act did not apply because the plaintiffs did not report a violation of law "by the employing governmental entity or another public employee." The court was not convinced, and the case proceeded to a jury trial, which resulted in a $4 million judgment for the plaintiffs. The city appealed, raising several issues, including the legal question of whether the Whistleblower Act applied in this case. The court of appeals affirmed the district court's decision.The Supreme Court of Texas reversed the judgment of the court of appeals. The court held that the Whistleblower Act did not protect the plaintiffs because they reported a violation of law by a lone city council member, not by the employing governmental entity or another public employee. The court found that the lone city council member lacked any authority to act on behalf of the city, and her actions could not be imputed to the city. Therefore, her violation of law was not a "violation of law by the employing governmental entity." The court concluded that the plaintiffs did not allege a viable claim under the Whistleblower Act, and rendered judgment for the city. View "CITY OF DENTON v. GRIM" on Justia Law

The case revolves around a construction dispute where several homeowners in the San Marcial neighborhood sued Oscar Renda Contracting, Inc., for negligence and gross negligence. The homeowners alleged that the company's misuse of heavy equipment and faulty construction techniques caused damage to their homes during the construction of a drainage pipeline. They sought actual damages to restore their properties and exemplary damages based on gross negligence.The trial court found Renda Contracting negligent and grossly negligent. However, the jury was not unanimous in deciding the amount of exemplary damages, with ten out of twelve jurors agreeing. Consequently, the trial court omitted exemplary damages from the judgment. The homeowners appealed, and the court of appeals reversed the decision, arguing that unanimity as to exemplary damages could be implied despite a divided verdict.The Supreme Court of Texas reversed the court of appeals' judgment and reinstated the trial court's judgment. The court held that under Section 41.003 of the Civil Practice and Remedies Code, a court may not imply a unanimous jury finding in imposing exemplary damages. The burden to secure a unanimous verdict is on the plaintiff and "may not be shifted." The court concluded that the plaintiff bears the burden to obtain the findings necessary to impose exemplary damages, including that the jury is unanimous as to any amount of exemplary damages awarded. It is the plaintiff who must challenge a divided verdict as infirm or in need of clarification. View "OSCAR RENDA CONTRACTING, INC. v. BRUCE" on Justia Law

The case revolves around the interpretation of the term "home" in the context of Medicaid eligibility. The applicants, Clyde and Dorothy Burt, sold their house to their daughter and son-in-law, Linda and Robby Wallace, and moved into a rental property owned by the Wallaces. Later, they moved into a skilled-nursing facility. After moving into the facility, the Burts used their cash assets to buy an undivided one-half interest in the house they had previously sold to the Wallaces. They then executed a Lady Bird deed in favor of the Wallaces, granting their newly acquired one-half interest back to the Wallaces, reserving an enhanced life estate. The Burts then applied for Medicaid assistance, but the Texas Health and Human Services Commission denied their claim, arguing that the property interest was not excluded from the calculation of resources for Medicaid eligibility.The trial court reversed the agency’s determination, and the court of appeals affirmed the trial court's decision. The court of appeals held that a property interest created after admission to a skilled-nursing facility can be excluded from the resources used to determine Medicaid eligibility if the applicant states an intent to live at the property in the future.The Supreme Court of Texas disagreed with the lower courts' interpretation. The court held that a “home” is the applicant’s principal place of residence before the claim for Medicaid assistance arises, coupled with the intent to reside there in the future. A property interest purchased with qualifying resources after the applicant moves to a skilled-nursing facility is an available resource for determining Medicaid eligibility under federal eligibility rules, as the property was not the applicant’s principal place of residence at the time the claim for benefits arose. The court reversed the judgment of the court of appeals and rendered judgment in favor of the Commission. View "TEXAS HEALTH AND HUMAN SERVICES COMMISSION v. ESTATE OF CLYDE L. BURT" on Justia Law