Justia Texas Supreme Court Opinion Summaries

The dispute involved neighboring commercial properties in Fort Worth, Texas. After a store was constructed on one property, the adjacent property began to experience flooding during rainfall, which led to silt and trash accumulation and eventually damaged the building and parking lot. The owner of the flooded property documented the issue over several years and sought remedies from the city, but received no resolution. Engineering reports concluded that the store’s drainage system caused increased groundwater and stormwater runoff onto the neighbor’s land.The owner of the flooded property sued the store owner and related parties for nuisance, trespass, negligent and intentional diversion of water, and violations of the Texas Water Code, seeking damages and permanent injunctive relief. Two groups of defendants moved for summary judgment, arguing that all claims were barred by the two-year statute of limitations. The District Court for Tarrant County granted both motions for summary judgment in separate orders, one of which explicitly stated it was final and disposed of all parties and claims. The trial court subsequently issued a clarifying order allowing for a permissive interlocutory appeal but did not clarify whether the summary judgment orders’ finality was undone.The Court of Appeals for the Second District of Texas determined that the trial court’s summary judgment was final and accepted appellate jurisdiction. It held that while the two-year statute of limitations barred claims for damages, it did not bar injunctive relief to abate a nuisance. Upon review, the Supreme Court of Texas held that appellate jurisdiction was proper because the summary judgment order was expressly final and was not undone by the subsequent clarifying order. On the merits, the Supreme Court determined that injunctive relief cannot be granted without an underlying cause of action, and that the two-year statute of limitations applies to all claims for damages and injunctions in this case. The judgment of the court of appeals was reversed, and the trial court’s judgment was reinstated. View "FAMILY DOLLAR STORES OF TEXAS, LLC v. JLMH INVESTMENTS, LLC" on Justia Law

A railroad switchman suffered a severe injury while working for Rail Link, Inc., leading to the amputation of his leg. He brought a suit against Rail Link under the Federal Employers’ Liability Act (FELA), alleging negligence and gross negligence related to workplace safety policies, training, and environment. Rail Link responded by moving for summary judgment, arguing that it was not a “common carrier by railroad” as required for liability under FELA. The trial court initially denied Rail Link’s motion but later reconsidered and referred the question of Rail Link’s common-carrier status to the federal Surface Transportation Board (STB). In its petition to the STB, Rail Link sought a determination of its status under the ICC Termination Act (ICCTA), not under FELA.The First Court of Appeals in Houston denied the injured worker’s petition for mandamus relief, finding that the trial court did not clearly abuse its discretion by referring the issue to the STB. The dissent disagreed, reasoning that the STB, as a rate-setting body, lacks jurisdiction to determine common-carrier status for the purpose of FELA liability. The STB stayed its own proceedings while the mandamus petition was under review.The Supreme Court of Texas was then asked to issue a writ of mandamus. The Court held that a trial court may only refer a question to an administrative agency if there is a clear legislative grant of concurrent jurisdiction to the agency regarding the specific issue. The Court found no statutory authority granting the STB jurisdiction to determine common-carrier status under FELA. Therefore, the trial court abused its discretion by making the referral. The Supreme Court of Texas conditionally granted mandamus relief, directing the trial court to vacate its referral order. View "IN RE REED" on Justia Law

A dentist who worked for a group of dental practices in Texas discovered what he alleged to be a scheme of fraudulent dental procedures billed to the Texas Medicaid program. After being promoted to a leadership role in 2019, he claimed to have uncovered practices where dentists were pressured to perform unnecessary fillings and bill them under specific ADA codes. The dentist filed a qui tam action under the Texas Health Care Program Fraud Prevention Act in 2021, naming the dental group, its management company, and related entities as defendants. The alleged scheme involved hiring dentists burdened by student debt and compensating them in ways that encouraged compliance with these practices.Previously, another employee had filed a similar qui tam action in Travis County in 2012, alleging a broader fraudulent scheme by the same dental group, including unnecessary procedures and improper billing. That action also involved a third-party payment processor and resulted in a large settlement with the State in 2019. The earlier action was still pending on appeal. After the dentist who filed the 2021 action died, the defendants moved to dismiss, arguing that the claim was extinguished by his death and barred by the earlier pending action, the public disclosure of fraud allegations, and the doctrine of dominant jurisdiction. The trial court denied all these motions, including substituting the deceased relator’s widow as representative, and the defendants sought mandamus relief in the Court of Appeals for the Fifteenth District of Texas, which denied their petition.The Supreme Court of Texas reviewed the petition for writ of mandamus. It held that qui tam claims under the Act survive the relator’s death because they belong to the State, not the individual relator. The Court also found that the defendants had not conclusively shown the later suit was based on the same facts as the earlier action, nor that public disclosure barred the claims. Finally, dominant jurisdiction did not require abatement. The Court denied the petition. View "IN RE TAFEL" on Justia Law

Several cities challenged recent Texas legislative changes that reduced the fees cities could charge telecommunications companies for using public property alongside city streets. The cities argued that requiring them to charge less than market rates for this use amounted to an unconstitutional gift to the telecom companies, contrary to the Texas Constitution’s Gift Clauses. Seeking a judicial declaration to this effect, the cities sued the State of Texas as the sole defendant, asserting that the statutory rate reductions were unconstitutional.At the trial level, the district court partially granted the cities’ request for a declaratory judgment. The Court of Appeals for the Third District of Texas went further, largely siding with the cities and holding that the statutory reductions violated the Gift Clauses. The State then sought review by the Supreme Court of Texas.The Supreme Court of Texas determined that the lower courts lacked jurisdiction over the case because the cities had sued the wrong defendant. The court explained that in constitutional challenges to state statutes, the proper defendant must be the officer or agency with authority to enforce the challenged law, not the State of Texas in the abstract. The court noted that the cities failed to identify any such officer or agency, and there was no indication that any state official had enforced or threatened to enforce the challenged statutes against the cities. Because a judgment against the “State of Texas” would not redress the cities’ alleged injuries nor bind the telecommunications companies, the dispute lacked the concrete adversarial parties necessary for a justiciable controversy. The Supreme Court of Texas vacated the judgments of the lower courts and dismissed the case for lack of jurisdiction. View "STATE v. CITY OF MCALLEN" on Justia Law

Emily Lehmberg sued Studio E. Architecture and Interiors, Inc. and other parties over the remodeling of her home. Studio E. moved to dismiss the claims against it, arguing that Lehmberg failed to file a certificate of merit as required by Texas Civil Practice and Remedies Code Section 150.002, which mandates such a certificate for claims against certain professionals. Lehmberg contended that her claims were not based on professional services but rather on alleged dishonesty and fraud. She also argued that Studio E. had waived its right to seek dismissal by waiting more than two years to file its motion. While the case against other defendants remained pending, the trial court denied Studio E.’s motion, and Studio E. filed an interlocutory appeal.The Court of Appeals for the Fourth District of Texas reversed the trial court’s decision, holding that Section 150.002 applied, and that Studio E. had not waived its right to seek dismissal. The appellate court remanded the case to the trial court to determine whether dismissal should be with or without prejudice. The trial court dismissed the original claims against Studio E. without prejudice, but allowed Lehmberg to file an amended petition with a certificate of merit, reasserting her claims. Studio E. moved to dismiss the amended petition, arguing that reassertion was not permitted in the same lawsuit, but the trial court denied the motion. Studio E. appealed again, and the court of appeals affirmed, holding that amending the petition was proper.The Supreme Court of Texas reviewed the case and held that when claims against a defendant are dismissed without prejudice under Section 150.002, and the underlying lawsuit remains pending, the plaintiff may reassert those claims in an amended petition along with a certificate of merit. The Court affirmed the judgment of the court of appeals. View "STUDIO E. ARCHITECTURE AND INTERIORS, INC. v. LEHMBERG" on Justia Law

Maurice and Ni-Ida Colter leased an apartment from Prairie Capital, LLC, with Huffman Asset Management, LLC (HAM) acting as property manager. After experiencing a severe roach infestation, the Colters sued both entities for damages. The Colters attempted to serve process on HAM and Prairie at their registered office addresses as listed with the Texas Secretary of State. After several unsuccessful attempts, including at an address listed in the lease, the Colters resorted to substituted service by delivering the lawsuit documents to the Secretary of State, as permitted when a registered agent cannot be found with reasonable diligence at the registered office.The 134th District Court of Dallas County granted a no-answer default judgment in favor of the Colters, sending notice to the address listed in the lease. HAM and Prairie only became aware of the lawsuit after receiving the default judgment and moved for a new trial, arguing that they were not properly served. The trial court denied their motion. On appeal, the Court of Appeals for the Fifth District of Texas held that the Colters had exercised reasonable diligence and that service through the Secretary of State was valid because the Secretary had forwarded process to the entities’ registered office addresses as shown in the Secretary’s Whitney certificates. The appellate court affirmed the default judgment except for a portion of the damages.The Supreme Court of Texas reviewed the case and held that, under the Texas Business Organizations Code, valid substituted service requires the Secretary of State to forward process to the “most recent address of the entity on file,” which may not necessarily be the registered office address. Since the Colters failed to ensure process was sent to the correct most recent address on file for both entities, the Court found the service defective. The Supreme Court of Texas reversed the court of appeals’ judgment and remanded the case to the trial court for further proceedings. View "HUFFMAN ASSET MANAGEMENT, LLC v. COLTER" on Justia Law

The dispute arose after the City approved a light rail project and formed a corporation, Austin Transit Partnership (ATP), to implement it. Voters approved a tax increase to fund the endeavor, and ATP—not the City—planned to issue municipal bonds. Taxpayers challenged ATP’s authority to issue these bonds, leading the City and ATP to seek a declaratory judgment confirming their power to assess taxes and issue bonds. The Attorney General, participating as permitted by statute, filed a plea to the jurisdiction, contending neither the City nor ATP qualified as an “issuer” under the statute governing expedited declaratory judgment actions.In the District Court, the City and ATP sought a quick resolution so the project could proceed, while the taxpayers and Attorney General desired delay. ATP’s counsel advised the court not to rule on the Attorney General’s plea to the jurisdiction, thus avoiding an interlocutory appeal and the associated automatic stay. The court accepted this suggestion, explicitly refusing to rule on the plea and moving forward toward trial. The Attorney General then filed a notice of interlocutory appeal, arguing the court’s actions amounted to an implicit denial. The trial court reiterated it had not ruled, and the Court of Appeals for the Fifteenth District dismissed the appeal, finding no order granting or denying the plea and therefore no appellate jurisdiction.The Supreme Court of Texas reviewed the case, holding that a trial court must rule on jurisdictional challenges before proceeding to the merits and cannot strategically avoid issuing a ruling to frustrate the government’s appellate rights. Because the absence of a ruling deprived the State of its statutory right to interlocutory appeal, and no adequate remedy by appeal existed, the Court treated the Attorney General’s petition as a request for mandamus and conditionally granted relief, directing the trial court to rule on the plea to the jurisdiction. The judgment of the Court of Appeals was left undisturbed. View "PAXTON v. THE CITY OF AUSTIN" on Justia Law

A woman was killed when a construction crane collapsed during a storm, striking her apartment building. Her parents, acting individually and on behalf of her estate, brought a negligence and gross negligence lawsuit against several defendants, primarily three related construction and development entities. Following a jury trial, the jury found these entities had engaged in a joint enterprise that caused the woman’s death and awarded over $360 million in compensatory damages, along with $500 million in exemplary damages (which the trial court later reduced under statutory caps). The court entered judgment holding the entities jointly and severally liable for the compensatory damages, with two entities also severally liable for exemplary damages.The defendants, collectively known as the Greystar Entities, filed a single $25 million joint supersedeas bond to suspend execution of the judgment during their appeal. The plaintiffs challenged the sufficiency of this joint bond in the 191st Judicial District Court, Dallas County, arguing that Texas law capped the required bond at $25 million per debtor, not per judgment. The trial court agreed, ruling that each entity needed to post its own $25 million bond and that the joint bond could suspend execution for only one entity unless the defendants designated which one. The Greystar Entities appealed to the Fifth Court of Appeals at Dallas, which affirmed the trial court’s order.The Supreme Court of Texas reviewed the case on a petition for writ of mandamus. The Court held that, under Texas Civil Practice and Remedies Code Section 52.006(b), the $25 million cap on supersedeas bonds applies per judgment debtor, not collectively to all debtors in a single judgment. The Court also held that the trial court abused its discretion by immediately invalidating the joint bond without allowing a reasonable time for compliance. The Supreme Court conditionally granted partial mandamus relief, directing the trial court to provide additional time for each entity to post an individual bond. View "IN RE GREYSTAR DEVELOPMENT & CONSTRUCTION, L.P." on Justia Law

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