Justia Texas Supreme Court Opinion Summaries

In this complaint alleging ultra vires claims against Mike Morath, in his official capacity as the Commissioner of the Texas Education Agency, the Supreme Court granted Respondents' motion to dismiss this appeal as moot, dismissed the case as moot, and vacated both the judgment and opinion of the court of appeals without respect to the merits, holding that the case must be dismissed as moot.Morath filed a plea to the jurisdiction, alleging that Respondents' claims could not proceed for several reasons. The trial court denied the plea to the jurisdiction, and the court of appeals affirmed. Morath petitioned for review. After Morath filed his merits brief, Respondents decided to stop pursuing their claims and filed a "notice of nonsuit without prejudice." Respondents then moved to dismiss the appeal as moot. Morath opposed the motion to dismiss, arguing that a non-suit was ineffective and, alternatively, that this appeal involved a matter of public concern. The Supreme Court dismissed the appeal, holding that that this case is now moot, and in the absence of jurisdiction this case must be dismissed. View "Morath v. Lewis" on Justia Law

The Supreme Court reversed the judgment of the court of appeals upholding the trial court's grant of summary judgment without addressing its legal merit, holding that the trial court's recital in its final summary judgment order that it considered "the pleadings, evidence, and arguments of counsel" included a late-filed response and attached evidence.Plaintiff sued Defendant alleging that she had been sexually assaulted at work. Defendant moved for summary judgment, presenting traditional and no evidence grounds. The trial court granted the motion. On remand from the Supreme Court, the court of appeals affirmed, concluding that Plaintiff failed to file a timely response to the no-evidence motion and that the trial court did not consider the late-filed response. The court of appeals declined to consider the evidence that Defendant had attached to its combined motion because no timely response pointed out a fact issue raised by that evidence. The Supreme Court reversed, holding (1) the trial court's recital that it considered the "evidence and arguments of counsel," without limitation, was an "affirmative indication" that the trial court considered Plaintiff's response and the evidence attached to it; and (2) therefore, the court of appeals should have considered that evidence as well in its review of the trial court's summary judgment. View "B.C. v. Stake N Shake Operations, Inc." on Justia Law

The Supreme Court reversed the judgment of the court of appeals ruling that, where the trial court granted a motion to dismiss without specifying the ground for its decision, the court of appeals did not have authority to order supplemental briefing but was instead required to affirm because of Appellants' failure to brief all possible grounds for the trial court's decision, holding that the court of appeals had the authority to order supplemental briefing.In this dispute over church assets, Appellees filed a motion to dismiss and a plea to the jurisdiction based on both standing and the ecclesiastical abstention doctrine. The trial court granted the motion but did not specify the grounds for its decision. Appellants appealed, but the appellate brief only addressed the standing issue. The court of appeals affirmed, holding that it lacked the authority to order supplemental briefing on the ecclesiastical abstention issue and was bound to affirm the trial court because Appellants failed to challenge all possible bases for the decision. The Supreme Court reversed, holding that because Appellants effectively raised the ecclesiastical abstention issue in their appellate briefing, the court of appeals had the authority to order additional briefing under Tex. R. App. P. 38.9. View "St. John Missionary Baptist Church v. Flakes" on Justia Law

In this venue dispute, the Supreme Court denied a petition for mandamus relief, holding that the trial court did not abuse its discretion in transferring the case to the parties' agreed venue.This case stemmed from a lawsuit alleging wrongful disposition of a limited partnership's assets. A group of the limited partners (collectively, Fox River) sued William Carlson, who owned and controlled the partnership's general partner, claiming that Carlson fraudulently misappropriated groundwater leases, breached the limited partnership agreement, and violated fiduciary duties. Fox River filed the lawsuit in Washington County where Carlson was domiciled. Carlson moved to transfer venue to Harris County, citing a venue-selection clause in the limited partnership agreement. The trial court granted the motion, enforcing the parties' venue agreement in accordance with Tex. Civ. Prac. & Rem. Code 15.020. Fox River sought mandamus relief, arguing that Tex. Civ. Prac. & Rem. Code 65.023(a) mandates venue in a defendant's county of domicile for cases primarily seeking injunctive relief. The Supreme Court denied mandamus relief, holding that section 15.020 requires enforcement of the parties' venue-selection agreement not because it is a "super mandatory" venue provision that supersedes section 65.023(a) but because section 65.023(a) does not apply in suits like this where injunctive relief is not the primary and principal relief requested. View "In re Fox River Real Estate Holdings, Inc." on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming summary judgment, not on the merits, but based on remediable record-citation errors in Appellant's brief, holding that the record citation errors should not have been fatal to the appeal absent a reasonable opportunity to cure the defects.In this litigation involving the dissolution of Robbie Lesa Hames Horton and Kimberly Stovall's personal and business relationship, Horton appealed a severance order and three summary judgments. The court of appeals affirmed, primarily faulting Horton for citing to documents in the appendix of her appellate brief instead of providing citations to the clerk's record. The Supreme Court reversed, holding that Horton was entitled to, at a minimum, a reasonable opportunity to correct the defective record citations in her appendix documents, which the court of appeals knew were actually included in the summary judgment record. View "Horton v. Stovall" on Justia Law

In this appeal of a $1.4 million sanction levied to compensate Respondents, the prevailing parties, for their attorney's fees in defending against a frivolous lawsuit, the Supreme Court reversed the court of appeals' judgment affirming the sanctions award and remanded the case to the trial court for further proceedings, holding that the standard for fee-shifting awards in Cf. Rohrmoos Venture v. UTSW DVA Healthcare, LLP, __ S.W.3d __ (Tex.2019), likewise applies to fee-shifting sanctions.In the first appeal, the Supreme Court concluded that Petitioner's pleadings were groundless and sanctionable and remanded for the trial court to reassess its award of attorney's fees. On remand, the trial court reassessed the same $1.4 million sanction originally granted for attorney's fees. On appeal, Petitioner argued that Respondents' affidavits were insufficient to prove that the $1.4 million sanction was a reasonable and necessary attorney's fee. In response, Respondents argued that a different standard of proof applies for attorney's fees awarded as sanctions because the purpose of sanctions is to punish violators and deter misconduct. The Supreme Court disagreed, holding that all fee-shifting situations require reasonableness and that conclusory affidavits containing mere generalities about the fees for working on Petitioner's frivolous claims are legally insufficient to justify the sanction awarded in this case. View "Nath v. Texas Children's Hospital" on Justia Law

The Supreme Court conditionally granted Appellant's petition for writ of mandamus where, while an interlocutory Texas Citizens Participation Act (TCPA) appeal was pending, the court of appeals granted Appellees' motion to lift a statutory stay for a limited purpose, holding the the court of appeals' order violated the statutory stay and that the relator had no adequate remedy by appeal.During certain interlocutory appeals, Tex. Civ. Prac. & Rem. Code 51.014(b), stays the commencement of a trial pending resolution of the appeal. For a subset of these interlocutory appeals, including appeals from the denial of a motion to dismiss under the TCPA, the statute also stays all other trial court proceedings pending resolution of that appeal. While an interlocutory TCPA appeal was pending, the court of appeals granted a motion to lift the statutory stay for the limited purpose of allowing the trial court to conduct a hearing on Appellees' request for temporary injunction and motion for contempt. Appellant filed a petition for a writ of mandamus. The Supreme Court conditionally granted the mandamus petition, holding that the court of appeals abused its discretion by authorizing the trial court to conduct further trial court proceedings in violation of the legislatively mandated stay of "all other proceedings in the trial court." View "In re Geomet Recycling LLC" on Justia Law

In this interlocutory appeal, the Supreme Court reversed in part the judgment of the court of appeals allowing the State's money-damages claims and its ultra vires claims to proceed against the Chambers-Liberty Counties Navigation District (District) and Sustainable Texas Oyster Resource Management, LLC (STORM), holding that governmental immunity barred the State's claim for monetary relief against the District but did not bar its ultra vires claim.The District leased submerged land to STORM for oyster production. The State sued the District and STORM seeking to invalidate the lease on the grounds that Texas law affords the Texas Parks and Wildlife Department the sole power to decide who may cultivate oysters in the area. The State also sought monetary relief. The District filed a plea to the jurisdiction, asserting that the District's immunity from suit barred the State's claims. The trial court denied the plea. The court of appeals reversed the portion of the trial court's order that permitted the State to pursue an ultra vires claim against the District itself and otherwise affirmed the denial of the plea to the jurisdiction. The Supreme Court reversed in part, holding that governmental immunity barred the State's claim for monetary relief against the District but did not bar its ultra vires claim. View "Chambers-Liberty Counties Navigation District v. State" on Justia Law

The Supreme Court remanded this case to the trial court for a redetermination of attorney's fees consistent with the Court's decision in Rohrmoos Venture v. UTSW DVA Healthcare, LLP, __ S.W.3d __ (Tex. 2019), also decided today, holding that, having clarified the law governing the award of attorney's fees, remand was necessary.Plaintiff brought a suit against Defendant for unpaid legal fees. The jury awarded the amount sought to Plaintiff. Plaintiff also sought attorney's fees pursuant to Tex. Civ. Prac. & Rem. Code 38.001. After hearing expert testimony about the reasonableness and necessity of the attorney's fees, the jury awarded attorney's fees. Defendant filed a motion for judgment notwithstanding the verdict, arguing that the evidence was legally insufficient to support the fee award. The trial court denied the motion, and the court of appeals affirmed. The Supreme Court reversed and remanded the case to the trial court for a redetermination of attorney's fees consistent with its decision in Rohrmoos Venture. View "Barnett v. Schiro" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the trial court granting Defendant's plea to the jurisdiction and dismissing a judicial-review claim that had been filed after the forty-five-day deadline to seek judicial review of a decision by a Division of Workers' Compensation appeals panel, holding that while the forty-five-day deadline is mandatory, it is not jurisdictional.Plaintiff sought workers' compensation benefits from Defendant, which disputed the claim. Plaintiff then initiated administrative proceedings. A hearing office found against Plaintiff, and Plaintiff appealed to an appeals panel. While the administrative proceedings were pending, Plaintiff filed a wrongful-death suit and then amended her probate-court pleadings, seeking judicial review of the administrative decision. Defendant successfully filed a plea to the jurisdiction. Plaintiff then filed suit against Defendant in district court seeking judicial review of the appeals panel decision. The district court granted Defendant's plea to the jurisdiction and dismissed Plaintiff's claims. The court of appeals reversed, holding that the forty-five-day deadline for filing judicial review claims is not a jurisdictional statutory prerequisite, and therefore, the trial court erred in granting Defendant's plea to the jurisdiction. The Supreme Court affirmed, holding that Plaintiff's failure to file suit before the forty-five-day deadline did not deprive the district court of jurisdiction. View "Texas Mutual Insurance Co. v. Chicas" on Justia Law