Justia Texas Supreme Court Opinion Summaries

The Supreme Court reversed in part the judgment of the court of appeals, which dismissed Petitioners’ appeal for lack of jurisdiction, holding that Petitioners timely filed their interlocutory appeal.Respondent filed suit against several parties, including Petitioners - municipal development corporations (MDCs) - alleging that negligent construction of a municipal hiking and walking path caused damming, resulting in damage to his property. Petitioners filed a motion to dismiss and plea to the jurisdiction, arguing that Respondent’s claims lacked a jurisdictional basis. The trial court granted the motion to dismiss as to some claims but denied relief as to all other claims. The MDCs subsequently filed a motion for summary judgment on the remaining claims for injunctive relief, arguing that Respondent’s claims lacked a jurisdictional basis and evidentiary merit. The trial court denied the motion, and the MDCs appealed. The court of appeals dismissed the MDCs’ appeal for lack of appellate jurisdiction. The Supreme Court reversed in part, holding that the MDCs’ hybrid motion for summary judgment was not a mere motion for reconsideration but, rather, a distinct motion that merited an independent twenty-day interlocutory appeal period. View "City of Magnolia 4A Economic Development Corp. v. Smedley" on Justia Law

Homeowners sued Builder for failing to construct their home in a good and workmanlike manner. Builder’s commercial general liability insurer (Insurer) refused to defend Builder in the suit. Judgment was granted in favor of Homeowners after a trial, and Builder assigned the majority of its claims against Insurer to Homeowners. Homeowners subsequently sought to recover the judgment from Insurer under the applicable policy. The trial court entered judgment in favor of Homeowners. The court of appeals affirmed. The Supreme Court reversed and, in the interests of justice, remanded the case to the trial court for a new trial, holding (1) the judgment against Builder was not binding on Insurer in this suit because it was not the product of a fully adversarial proceeding; but (2) this insurance litigation may serve to determine Insurer’s liability, although the parties in the case focused on other issues during the trial. View "Great American Insurance Co. v. Hamel" on Justia Law

A party’s attorney-billing information is normally not discoverable when the party challenges an opposing party’s attorney-fee request as unreasonable or unnecessary but neither uses its own attorney fees as a comparator nor seeks to recover any portion of its own attorney fees.Several lawsuits brought by insured homeowners against various insurers and claims adjustors alleging underpayment of insured property-damage claims were consolidated into a single multidistrict litigation (MDL) for pretrial proceedings, including discovery. In this discovery dispute, individual homeowners sought attorney fees incurred in prosecuting their claims. The homeowners sought discovery regarding the insurer’s attorney-billing information. The insurer argued that the requested discovery was overly broad and sought information that was both irrelevant and protected by the attorney-client and work-product privileges. The MDL pretrial court ordered the insurer to respond to the discovery requests. The court of appeals denied the insurer’s petition for mandamus relief. The Supreme Court conditionally granted mandamus relief and directed the trial court to vacate its discovery order, holding that, absent unusual circumstances, information about an opposing party’s attorney fees and expenses is privileged or irrelevant and, thus, not discoverable. View "In re National Lloyds Insurance Co." on Justia Law

The Supreme Court took the opportunity in these consolidated mandamus proceedings to provide further clarity regarding electronically stored information (ESI) discovery.In this dispute, the requesting party sought ESI in native form while the responding party offered to produce the ESI in searchable static form, which the responding party asserted was more accessible and convenient given its routine business practices. The trial court ordered production in native form subject to a showing of infeasibility. The court of appeals denied mandamus relief. The Supreme Court denied the petitions for mandamus relief without prejudice, offering the responding party an opportunity to once again object to the discovery in light of this opinion, holding that evidence that a reasonably usable alternative form of ESI is readily available gives rise to the need for balancing, and if the factors outlined in this opinion preponderate against production in the requested form, the trial court may order production as requested under certain circumstances, but otherwise the responding party need only produce the data reasonably available in the ordinary course of business in reasonably usable form. View "In re State Farm Lloyds" on Justia Law

Certain minority shareholders filed suit in a Texas court alleging dilution of equity interests. Defendants responded by invoking a forum-selection clause designating Delaware as the proper forum for disputes arising out of a shareholders agreement. The court of appeals reversed the trial court’s grant of Defendants’ motion to dismiss, concluding that the forum-selection clause did not control because the shareholders’ extracontractual claims did not allege noncompliance or interference with any rights or obligations derived from the shareholders agreement. The Supreme Court reversed and dismissed the shareholders’ claims in part, holding (1) the shareholders’ statutory and common-law tort claims evidence a “dispute arising out of” the shareholders agreement; and (2) the shareholders’ noncontractual claims fell within the forum-selection clause’s scope. View "Pinto Technology Ventures, LP v. Sheldon" on Justia Law

At issue was whether a private university that operates a state-authorized police department is a “governmental unit” for purposes of Tex. Civ. Prac. & Rem. Code 51.014(a)(8), which provides for an interlocutory appeal from an order that “grants or denies a plea to the jurisdiction by a governmental unit.” The private university in this case was the University of the Incarnate Word (UIW), and the case arose from an UIW officer’s use of deadly force following a traffic stop. The parents of the UIW student killed in the incident sued UIW for their son’s death. UIW raised governmental immunity as a defense and asked the trial court to dismiss the suit in a plea to the jurisdiction. The trial court denied the plea. UIW took an interlocutory appeal under section 51.014(a)(8). The court of appeals dismissed the appeal. The Supreme Court reversed, holding that UIW is a governmental unit for purposes of law enforcement and is therefore entitled to pursue an interlocutory appeal under section 51.014(a)(8). View "University of the Incarnate Word v. Redus" on Justia Law

Tex. Civ. Prac. Rem. Code 150.002 provides that if an expert affidavit in a lawsuit or arbitration for damages arising out of the provision of professional services by licensed or registered professionals is not filed in accordance with the statute, the trial court shall dismiss the claim, and the dismissal may be with prejudice. The Supreme Court held that the statute affords trial courts discretion to dismiss either with or without prejudice. In this case, the statute required dismissal of the amended petition against Defendant. The trial court dismissed the claims without prejudice, but the court of appeals dismissed them with prejudice because, while the amended petition was accompanied by an expert affidavit, an expert affidavit was not filed with the original petition. The Court held that the trial court did not abuse its discretion by dismissing the claims with prejudice, as the record did not conclusively demonstrate that Plaintiff’s claims lacked merit or that the trial court’s decision violated any guiding rules and principles and therefore was an abuse of discretion. View "Pedernal Energy, LLC v. Bruington" on Justia Law

Several related nonresident corporate defendants entered into an agreement with Texas companies to settle a New York lawsuit. In the underlying suit, Plaintiff, a nonresident, alleged that, by virtue of the settlement agreement, the parties to the agreement tortiously interfered with another nonresident company’s indemnity obligations to Plaintiff. To support Texas’s specific jurisdiction over the nonresident defendants, Plaintiff alleged that the agreement was partially negotiated in Texas and substantially performed in Texas. The nonresident corporate defendants filed special appearances. The trial court denied the special appearances, concluding that Texas had specific jurisdiction over the nonresident defendants. The court of appeals affirmed. The Supreme Court reversed, holding that the court of appeals erred in concluding that the trial court had specific jurisdiction over the nonresident defendants in this suit. Remanded. View "M&F Worldwide Corp. v. Pepsi-Cola Metropolitan Bottling Co." on Justia Law

An oil-and-gas lessor sued the lessee for failure to pay royalties. The trial court concluded that the lessor’s neighboring landowners were necessary parties to the suit and dismissed the case without prejudice because the lessor failed to join them. The court of appeals affirmed, concluding that the trial court did not abuse its discretion in requiring joinder. The Supreme Court reversed, holding that the trial court abuse its discretion in requiring joinder under Tex. R. Civ. P. 39 and dismissing the case because the adjacent landowners did not claim an interest relating to the subject of the lessor’s suit against the lessee. Remanded for further proceedings. View "Crawford v. XTO Energy, Inc" on Justia Law

Rigney Construction & Development, LLC contracted with Red Dot Building System, Inc. for a portion of a school construction project. A dispute arose as to the scope of the work Red Dot was to perform under the contract. Red Dot later sued Rigney in Henderson County district court for an unpaid invoice. Thereafter, Rigney sued Red Dot in Hidalgo County. All of the claims related to the contract with Red Dot. Red Dot asked the Hidalgo County court to transfer the suit to Henderson County or abate the suit. The Hidalgo County court denied the motions to transfer and abate. Both courts set their cases for trial. Red Dot sought mandamus relief and, alternatively, asked the Supreme Court to instruct the Hidalgo County court to transfer its case to Henderson County or to abate the Hidalgo County suit. The Supreme Court granted mandamus relief insofar as Red Dot asked the Court to order the Hidalgo County court to transfer the case to Henderson County, holding that Hidalgo County court should have abated the suit pending in that court because Henderson County court acquired dominant jurisdiction. View "In re Red Dot Building System, Inc." on Justia Law