Justia Texas Supreme Court Opinion Summaries

A young man died after his motorcycle collided with a tractor-trailer owned and operated by a nationwide commercial motor carrier. The victim’s parents and his estate brought a wrongful-death and survival action against the trucking company, its driver, and a customer whose goods were being transported at the time of the accident. The plaintiffs alleged that the customer was negligent for hiring the trucking company, claiming it should have known the carrier employed reckless drivers due to a history of safety violations. However, the pleadings did not allege that the customer owned, operated, or controlled the truck, employed the driver, influenced how the shipment was conducted, or that the shipment itself involved any unusual risk or hazard.The trucking company and driver were sued for negligence and gross negligence. The plaintiffs later amended their petition to name the customer (a national retailer) as a defendant on the same theories. The customer moved to dismiss the claims under Texas Rule of Civil Procedure 91a, arguing it owed no duty of care to the public as a mere shipper of goods transported by an independent, federally regulated carrier. The trial court denied the motion to dismiss, and the Fourteenth Court of Appeals summarily denied mandamus relief.The Supreme Court of Texas reviewed the case on petition for writ of mandamus. It held that Texas law does not impose a duty of care on a passive shipper in these circumstances. The court concluded that because the customer neither created nor controlled the risk, and the allegations did not show any exception to the general rule against liability for acts of independent contractors, the claims against the customer had no basis in law. The Supreme Court of Texas conditionally granted mandamus relief, directing the trial court to vacate its denial and dismiss the claims against the customer. View "IN RE HOME DEPOT U.S.A., INC." on Justia Law

An Oklahoma company, formed to acquire mineral rights in Appalachia, alleged that two Texas parties failed to convey certain West Virginia mineral interests as contractually agreed. The Oklahoma company, which included non-Texas owners and participants, had funded the purchase of these rights, but a number of mineral deeds were recorded in the name of the Texas seller rather than the buyer. As a result, royalties from those mineral rights were paid to the seller. The Oklahoma plaintiff sought to compel the Texas defendants to reform the deeds, perform their contractual obligations, declare the plaintiff’s entitlement to the royalties, and enjoin the defendants from transferring the disputed interests.The 141st District Court in Tarrant County, Texas, denied the defendants’ plea to the jurisdiction and ultimately granted summary judgment for the plaintiff, awarding specific performance, deed reformation, declaratory relief, an injunction, and monetary relief. The court found it had jurisdiction over the parties and the contract, even though the mineral rights were located in West Virginia. On appeal, the Court of Appeals for the Second District of Texas reversed, holding that Texas courts lacked subject-matter jurisdiction because the suit’s gravamen was the adjudication of title to foreign (West Virginia) real property.The Supreme Court of Texas reviewed the matter and disagreed with the appellate court’s application of the so-called “gist” rule. The Supreme Court held that Texas courts with personal jurisdiction over the parties may issue in personam judgments concerning contractual obligations to convey out-of-state real property, as long as the judgment binds only the parties and does not purport to establish or alter title to the property by the court’s own force. The Supreme Court reversed the appellate court’s judgment and remanded for consideration of remaining issues. View "BRAXTON MINERALS III, LLC v. BAUER" on Justia Law

After the Texas Legislature enacted Senate Bill 8, which created a private civil enforcement mechanism for certain abortion restrictions, the Lilith Fund for Reproductive Equity’s deputy director made a sworn statement indicating the Fund had paid for abortions potentially in violation of that law. In response, Sadie Weldon filed a Rule 202 petition in Jack County seeking to depose the deputy director and obtain documents related to possible violations of the statute. While Weldon's petition was pending, the Lilith Fund initiated a lawsuit against Weldon, seeking a declaratory judgment that the statute was unconstitutional, as well as injunctive relief to prevent Weldon from pursuing related legal actions.The trial court denied Weldon’s Rule 202 petition, and Weldon subsequently filed a motion to dismiss the Lilith Fund’s suit under the Texas Citizens Participation Act (TCPA), which aims to quickly dispose of lawsuits that chill the exercise of free speech, association, or petition. The trial court did not rule on Weldon’s TCPA motion, resulting in its denial by operation of law. Weldon appealed, but the Court of Appeals for the Second District of Texas affirmed the denial, holding that the TCPA did not apply because the Fund’s suit was not “based on or in response to” Weldon’s Rule 202 petition.The Supreme Court of Texas reviewed the case and held that the TCPA does apply. The Court found that the Fund’s legal action was indeed “based on or in response to” Weldon’s exercise of her right to petition, as her Rule 202 petition was a protected activity under the statute and the Fund’s lawsuit sought relief directly connected to that petition. As a result, the Supreme Court of Texas reversed the judgment of the court of appeals and remanded the case for further proceedings under the remaining steps of the TCPA analysis. View "WELDON v. THE LILITH FUND FOR REPRODUCTIVE EQUITY" on Justia Law

A company providing paratransit and microtransit services under contract with a regional public transportation authority subcontracted another company to supply vehicles and drivers. After several months, the subcontractor terminated the agreement and brought suit against the transportation company and the authority, asserting claims including breach of contract, quantum meruit, tortious interference, fraud, and negligent misrepresentation. The fraud claim centered on alleged false representations made to induce the subcontract.The trial court (Texas District Court) ruled on a motion to dismiss under Texas Rule of Civil Procedure 91a, which allows dismissal if pleadings show no legal or factual basis for relief. The court dismissed the fraud and other tort claims against all defendants, as well as the breach of contract claim against the transportation authority and its primary contractor. It limited potential contract damages as to the contractor’s subsidiary and severed and abated remaining claims. The subcontractor appealed the dismissal of its claims against the main transportation company.The Court of Appeals for the Fifth District of Texas reversed in part, finding that the breach of contract and fraud claims against the main transportation company had a basis in law and that its statutory immunity under Texas Transportation Code § 452.056(d) was not conclusively established. The Supreme Court of Texas, reviewing only the fraud claim, held that the statutory immunity did apply. Because the pleadings showed the transportation company was contractually performing the authority’s function, and the authority itself would be immune from a fraud claim (an intentional tort), the company was likewise immune from liability for fraud. Accordingly, the Supreme Court of Texas reversed the Court of Appeals’ judgment and reinstated the trial court’s dismissal of the fraud claim. The case was remanded for further proceedings on any remaining claims. View "MV TRANSPORTATION, INC. v. GDS TRANSPORT, LLC" on Justia Law

A business dispute arose when an employee hired to supervise construction projects for a company was found to be diverting workers, who were being paid by the company, to work on personal construction ventures organized jointly with others. This scheme was uncovered after discrepancies in worksite attendance were noticed and investigated. The company then sued the parties involved for theft of services, tortious interference, and unjust enrichment, alleging that the defendants benefited from the misappropriated labor. During the litigation, it was discovered that some potentially relevant business records and emails were unavailable, leading to further disputes about whether these materials were intentionally withheld to prevent discovery.Following a jury trial in the 68th District Court of Dallas County, the jury found in favor of the plaintiff company and awarded damages. The defendants, Copper Creek Distributors, Inc. and Escoffie, appealed to the Court of Appeals for the Fifth District of Texas. On appeal, they raised several issues, including challenges to the sufficiency and admissibility of damages evidence, liability findings, and procedural matters. However, the court of appeals only addressed the trial court’s decision to give a spoliation instruction to the jury, found it to be erroneous and harmful, and remanded for a new trial, without considering other appellate points that could warrant rendering judgment for the appellants.The Supreme Court of Texas reviewed the case and held that appellate courts must address issues that could require rendition before remanding for a new trial. The court concluded that the court of appeals erred by not first considering other grounds that might have fully resolved the case. The Supreme Court also found the harm analysis regarding the spoliation instruction inadequate. Therefore, it reversed the court of appeals’ judgment and remanded the case for further proceedings consistent with its opinion. View "VALK v. COPPER CREEK DISTRIBUTORS, INC." on Justia Law

GAC Equipment, doing business as Austin Crane Service, hired Diamond Hydraulics to repair a crane’s cylinder, which later bent during a lifting operation. Each party blamed the other: Diamond argued that improper maintenance and operation by Austin Crane caused the failure, while Austin Crane claimed Diamond’s repairs were improper and used unsuitable materials. The dispute intensified during discovery, particularly over Diamond's ability to inspect the cylinder, and both parties made late expert witness designations. As trial approached, Diamond’s designated expert, Dr. Macfarlan, left his job, moved out of state, and refused to testify. Diamond attempted to substitute another expert, Dr. Hoerner, who had participated in preparing the expert report. Austin Crane objected, and the district court denied Diamond’s request to substitute its expert and to continue the trial.The 425th Judicial District Court in Williamson County, Texas, proceeded with the trial without Diamond’s causation expert. The jury found in favor of Austin Crane on both breach of contract and breach of warranty claims. Diamond appealed, arguing that the district court abused its discretion by not allowing the late expert substitution. The Court of Appeals for the Third District of Texas affirmed the trial court’s decision.The Supreme Court of Texas reviewed the case, focusing on whether Diamond showed good cause for its late expert designation under Texas Rule of Civil Procedure 193.6. The Supreme Court held that Diamond demonstrated good cause: the unavailability of Diamond’s original expert was beyond its control, Diamond acted promptly and in good faith to substitute an expert, and the excluded testimony was critical to its case. The Supreme Court concluded that the district court abused its discretion and that disparate treatment was given to the parties’ late designations. The Supreme Court of Texas reversed the court of appeals’ judgment and remanded the case for a new trial. View "DIAMOND HYDRAULICS, INC. v. GAC EQUIPMENT, LLC" on Justia Law

Following Hurricane Laura, a Texas-based company, Top Notch Movers, provided moving services in Alabama and Louisiana to Shamrock Enterprises, an Alabama-based LLC. Top Notch sent a demand letter to Shamrock seeking payment for over $170,000 in unpaid invoices. Subsequently, Top Notch filed suit in Texas for nonpayment, listing Shamrock’s principal office as a Foley, Alabama address and seeking substituted service via the Texas Secretary of State under section 5.251(1)(A) of the Texas Business Organizations Code. The Secretary of State attempted to forward process to the Foley address, but the mailing was returned as undeliverable. Shamrock did not appear, and Top Notch obtained a default judgment, which was also mailed to the same address and returned.Shamrock later initiated a restricted appeal, arguing that service of process was improper. The Court of Appeals for the Thirteenth District of Texas affirmed the default judgment, finding that Shamrock was amenable to substituted service under the cited statute and that the Secretary of State’s Whitney certificate constituted irrebuttable proof of proper service.The Supreme Court of Texas reviewed the case and determined that even if Shamrock was subject to substituted service under section 5.251(1)(A), the record did not show that process was forwarded to the statutorily required address—Shamrock’s “most recent address . . . on file with the secretary of state.” The court clarified that a Whitney certificate only proves that process was sent to the address provided, not that the statutory requirements were met, and strict compliance is necessary for a valid default judgment. Therefore, the Supreme Court of Texas reversed the judgment of the Court of Appeals, vacated the default judgment, and remanded the case to the trial court for further proceedings. View "SHAMROCK ENTERPRISES, LLC v. TOP NOTCH MOVERS, LLC" on Justia Law

A Maryland real estate investment trust with over 12,000 shareholders entered into an advisory agreement with UMTH General Services, L.P. and its affiliates to manage the trust’s investments and operations. The agreement stated that the advisor was in a fiduciary relationship with the trust and its shareholders, but individual shareholders were not parties to the agreement. After allegations of mismanagement and improper advancement of legal fees surfaced, a shareholder, Nexpoint Diversified Real Estate Trust, sued derivatively in Maryland. The Maryland court dismissed the claims for lack of standing and subject matter jurisdiction. Nexpoint then transferred its shares to a subsidiary, which, along with Nexpoint, sued the advisors directly in Texas, alleging corporate waste and mismanagement, and claimed the advisory agreement created a duty to individual shareholders.In the 191st District Court of Dallas County, the advisors filed a plea to the jurisdiction, a verified plea in abatement, and special exceptions, arguing that the claims were derivative and belonged to the trust, so the shareholders lacked standing and capacity to sue directly. The trial court denied these motions. The advisors sought mandamus relief from the Fifth Court of Appeals, which was denied, and then petitioned the Supreme Court of Texas.The Supreme Court of Texas held that while the shareholders alleged a financial injury sufficient for constitutional standing, they lacked the capacity to sue individually because the advisory agreement did not create a duty to individual shareholders, nor did it confer third-party beneficiary status. The agreement benefited shareholders collectively through the trust, not individually. The court conditionally granted mandamus relief, directing the trial court to vacate its order and dismiss the case with prejudice, holding that shareholders must pursue such claims derivatively and in the proper forum as specified by the trust’s governing documents. View "IN RE UMTH GENERAL SERVICES, L.P." on Justia Law

A mother, referred to as D.V., had a history of violent behavior and drug use. After she allegedly assaulted her ex-boyfriend and one of her other children, the Texas Department of Family and Protective Services took custody of her child, E.D., and filed a petition to terminate both parents’ rights. By the time of trial, the Department had decided to seek termination only as to the mother, but at trial, its designated representative twice stated unequivocally that the Department was not seeking termination of the mother’s rights, but instead sought to limit and restrict her rights, appointing the father as sole managing conservator. The Department’s live pleading still requested termination, but no party at trial treated that as the Department’s actual position.The case was first heard by an associate judge, who conducted a bench trial and ordered termination of the mother’s parental rights. The mother sought a de novo hearing in the district court, which adopted the associate judge’s ruling. The Court of Appeals for the Third District of Texas affirmed, reasoning that the Department’s abandonment of its termination request was not unequivocal when considering the totality of the circumstances, including recommendations from other parties and the Department’s live pleading.The Supreme Court of Texas reversed the court of appeals. It held that in parental-termination cases, a court may not terminate parental rights when the Department, through its designated representative, makes an unequivocal and unrepudiated statement at trial withdrawing termination as a requested form of relief. The Court rendered judgment in accordance with the Department’s stated position at trial and remanded the case to the district court to enter judgment consistent with this holding and to resolve any remaining issues. View "D.V. v. TEXAS DEPARTMENT OF FAMILY AND PROTECTIVE SERVICES" on Justia Law

A candidate for Congress, who holds both a medical degree and a law degree but is not licensed to practice medicine, referred to himself as “Dr. Gonzalez” and a “physician” during his campaign. The Texas Medical Board (TMB) received a complaint alleging that these statements constituted the unlicensed practice of medicine and improper use of professional titles. After an investigation and hearing, TMB determined that the candidate had violated the Medical Practice Act and the Healing Art Identification Act, issuing a cease-and-desist order prohibiting him from using the titles “doctor,” “physician,” or “Dr.” without clarifying his lack of a medical license. The candidate challenged the order, arguing both statutory and constitutional grounds, including that the statutes violated his free speech rights.The Travis County District Court dismissed all of the candidate’s claims for lack of jurisdiction. The Court of Appeals for the Third District of Texas affirmed the dismissal of most claims, holding that the redundant-remedies doctrine barred his ultra vires and as-applied constitutional claims because he could have sought relief through the Administrative Procedure Act (APA). However, the appellate court remanded his facial constitutional challenge to the district court for further proceedings.The Supreme Court of Texas reviewed the case and held that the redundant-remedies doctrine did not bar the candidate’s ultra vires and as-applied constitutional claims, because the relief he sought—declaratory and injunctive relief against future enforcement—went beyond what the APA could provide. The court affirmed the dismissal of his substantial-evidence claim for lack of jurisdiction, as there was no statutory basis for judicial review outside the APA. The Supreme Court of Texas reversed in part, affirmed in part, and remanded for further proceedings on the facial constitutional, as-applied constitutional, and ultra vires claims. View "GONZALEZ v. TEXAS MEDICAL BOARD" on Justia Law