Justia Texas Supreme Court Opinion Summaries

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

The Supreme Court reversed the judgment of the court of appeals that the parol evidence rule barred evidence and enforcement of an agreement through which Plaintiff claims to have satisfied his debt to Defendant, holding that the parol evidence rule did not preclude enforcement of the agreement, and therefore, Plaintiff met his burden to establish a prima facie case for the falsity of Defendant's liens.Plaintiff brought this action claiming that after he fully satisfied his debt to Defendant, Defendant filed fraudulent liens and knowingly and intentionally slandered Plaintiff's title to mineral interests that secured that debt. Defendant filed a motion to dismiss the claims, arguing that Plaintiff could not establish prima facie support for his slander-of-title and fraudulent-lien claims because the parol evidence rule applied and precluded Plaintiff from establishing any enforceable agreement that satisfied his debt. The trial court denied the motion. The court of appeals affirmed. The Supreme Court reversed, holding that the parol evidence rule did not preclude enforcement of the agreement through which Plaintiff claimed to have satisfied his debt to Defendant, and that Plaintiff thus met his burden to establish a prima facie case for the falsity of Defendant's liens. View "West v. Quintanilla" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the judgment of the court of appeals holding that an interlocutory order denying a motion for summary judgment based on a claim against or defense by a member of the media or personal quoted by the media involving constitutional guarantees of freedom of speech or of the press refers to the ruling on the entire motion, including nonconstitutional grounds, and Defendants were entitled to summary judgment on all claims against them.Plaintiff sued a publication and an orchestra alleging various tort claims. Defendants each moved for summary judgment on all of Plaintiff’s claims. The trial court granted the motions in part but denied the publication’s motion on Plaintiff’s claims for defamation, conspiracy to defame, negligence, and gross negligence and denied the orchestra’s motion on Plaintiff’s claims for conspiracy to defame and tortious interference with employment. Defendants appealed based on Tex. Civ. Prac. & Rem. Code 51.014(a)(6). Some of Defendants’ defenses arose under constitutional guarantees of free speech and a free press, but others did not. The court reversed the denial of the publication’s motion for summary judgment and part of the denial of the orchestra’s motion. The Supreme Court reversed in part, holding that Defendants were entitled to summary judgment on all of Plaintiff’s claims. View "Dallas Symphony Ass’n v. Reyes" on Justia Law

In this attorney-disqualification dispute, the Supreme Court directed the court of appeals to vacate its order directing the trial court to reconsider the merits of disqualification using the factors set forth in In re Meador, 968 S.W.2d 346 (Tex. 1998), holding that the trial court did not clearly abuse its discretion in declining to do so.The first time the Supreme Court addressed the disqualification in this case, the Court held that the trial improperly applied the presumption-based standard in In re American Home Products Corp., 985 S.W.2d 68 (Tex. 1998), to disqualify Plaintiffs’ counsel. Defendants filed a motion to reconsider disqualification under Meador. The trial court denied the request for reconsideration as “untimely, dilatory in nature, and/or waived.” The court of appeals directed the trial court to vacate its order and determined the motion to reconsider on the merits under Meador. The Supreme Court conditionally granted mandamus relief, holding that because Defendants initially sought disqualification based on Meador but later abandoned and affirmatively opposed any consideration under Meador, the trial court did not clearly abuse its discretion in concluding that Defendants were not entitled to a do-over under the circumstances. View "In re RSR Corp." on Justia Law

The Supreme Court affirmed the trial court’s denial of Sabre Travel International, Ltd.’s motion to dismiss Deutsche Lufthansa Airline Group’s tortious interference with contract claim based on preemption, holding that the federal Airline Deregulation Act (ADA) did not preempt an airline’s claim for tortious interference with contract brought under state law.The trial court denied Sabre’s motion to dismiss but certified a legal question under Tex. Civ. Prac. & Rem. Code 51.014(d) providing for permissive interlocutory appeals. The court of appeals denied the permissive interlocutory appeal without explanation. After Sabre filed a petition for review in the Supreme Court, Lufthansa argued that the Court had no jurisdiction to hear the case because the court of appeals denied the permissive appeal. The Supreme Court held (1) under Tex. Gov. Code 22.225(d), an appellate court’s denial of a permissive interlocutory appeal does not prevent the Supreme Court from reviewing the merits of the interlocutory order; and (2) there was no preemption under the ADA. View "Sabre Travel International, Ltd. v. Deutsche Lufthansa AG" on Justia Law