Justia Texas Supreme Court Opinion Summaries

The Supreme Court conditionally granted Relator American Airlines, Inc.'s petition for a writ of mandamus seeking relief from an order compelling the oral deposition of a high-level corporation official, holding that Relator was entitled to relief.The real party in interest in this case, Dr. Donald Arnette, sued American, alleging that one of its gate agents had improperly accessed his personal information and used it to harass him. Arnette served American with a series of deposition notices for Elise Eberwein, one of the six officers on American's executive leadership team. After a hearing, the trial court issued an order requiring Arnette to serve a new deposition notice. When eight months had passed without service of the required deposition notice American filed a petition for writ of mandamus seeking relief from the trial court's order. The Supreme Court conditionally granted relief and directed the trial court to vacate the order compelling Eberwein's deposition, holding that the trial court abused its discretion in compelling Eberwein's testimony. View "In re American Airlines, Inc." on Justia Law

The Supreme Court reversed the decision of the court of appeals dismissing the appeal in this bill-of-review proceeding for want of jurisdiction, holding that the court of appeals erred in ruling that the trial court's order dismissing the bill-of-review petition was interlocutory.The court of appeals held that the trial court order dismissing the bill-of-review petition was not final because the trial court failed to include decree-like language adjudicating and disposing of the petition. The Supreme Court reversed, holding that the order was final where it (1) disposed of all claims and parties; (2) stated that it was a "final order"; and (3) declared that the legal effect of granting the motions to dismiss was the dismissal of the bill of review filed in the instant case. View "In re Guardianship of Jones" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the trial court concluding that service on WWLC Investment, LP by Sorab Miraki was not defective, holding that WWLC met its burden to prove lack of proper service.After WWLC had Miraki evicted, Miraki sued for breach of lease, fraud, and violations of the Texas Deceptive Trade Practices Act, Tex. Bus. & Com. Code ch. 17. Miraki accomplished substituted service by attaching a copy of the petition and citation to the front door of the home of an WWLC employee. When WWLC did not answer, Miraki took a default judgment against it. The court of appeals concluded that the trial court did not abuse its discretion in finding that service on WWLC was not defective. The Supreme Court reversed, holding that WWLC demonstrated that it was not properly served. View "WWLC Investment, LP v. Miraki" on Justia Law

The Supreme Court granted Petitioner's petition for writ of habeas corpus and ordered that Petitioner is and shall remain discharged from custody, holding that the subject temporary restraining order's lack of specificity regarding the conduct to be restrained rendered it and the judgment of contempt and order of confinement void.Petitioner was jailed and her solely-owned business, a cosmetology salon, was fined for violating a temporary restraining order requiring them to cease and desist for operating the salon for in-person services in violation of regulations related to the COVID-19 pandemic. The trial court issued a judgment holding Petitioner and her business in contempt. Petitioner filed this habeas corpus petition arguing that she was illegally restrained because the temporary restraining order was unconstitutional and void. The Supreme Court agreed, holding (1) the temporary order was void; and (2) therefore, the contempt judgment based on that order was void as well. View "In re Luther" on Justia Law

The Supreme Court denied Relators' request for mandamus relief, holding that Tex. Gov't Code 22.004(i)'s prohibition on counter-supersedes refers to a particular procedural process, not an appellate court's temporary orders under other authority.In this ultra vires dispute, state regulators appealed an adverse temporary injunction. The trial court allowed Plaintiff, a school district, to counter-supersede the injunction so the regulators could not undertake unauthorized actions absent success on appeal. The court of appeals reversed the counter-supersedeas order, concluding that it was contrary to section 22.004(i) and Tex. R. App. P. 24.2(a)(3), but issued its own temporary order continuing the injunction pending disposition of the appeal. The Supreme Court denied mandamus relief, holding that the appellate court's temporary order did not conflict with section 22.004(i) because it was not counter-supersedes relief within the meaning of the statute. View "In re Texas Education Agency" on Justia Law

The Supreme Court reversed the judgment of the court of appeals holding that the trial court lacked jurisdiction over claims of a limited partner for harm done to the partnership because he lacked standing to bring the claims individually, holding that the appeal should be reconsidered in light of Pike v. Texas EMC Management, LLC, 610 S.W.3d 763 (Tex. 2020).Plaintiff formed multiple real estate-related partnerships and then sued his partners, later adding the partnerships as plaintiffs. Defendants filed a plea to the jurisdiction, asserting that Plaintiff individually lacked standing to bring claims against the individual individuals because the claims belonged to the partnerships. The trial court denied the plea. The court of appeals reversed and dismissed Plaintiff's individual claims for lack of jurisdiction, concluding that Defendant lacked standing to assert his original individual claims and that the doctrine of relation back could not create jurisdiction where none existed. The Supreme Court reversed, holding that the court of appeals' holding regarding standing was in direct conflict with Pike. View "Cooke v. Karlseng" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing a jury's finding that Jeffery Lee Stoddard was a sexually violent predator (SVP) and civilly committing him under Tex. Health & Safety Code chapter 841, holding that the court of appeals applied an improper standard.The court of appeals described the standard governing the factual sufficiency review in which the burden of proof was beyond a reasonable doubt the court of appeals described the standard as requiring the court to weigh the evidence in a neutral light to determined whether the jury's finding was factually insufficient or so against the great weight and preponderance as to be manifestly unjust, shock the conscience, or clearly demonstrate bias. The Supreme Court reversed, holding (1) the court of appeals applied an improper standard that allowed the court to substitute its own judgment for that of a reasonable fact-finder and incorporated a statutory element that chapter 841's text did not support; and (2) a properly conducted factual-sufficiency review in an SVP case requires the appellate court to determine whether, on the entire record, a reasonable factfinder could find beyond a reasonable doubt that the defendant is an SVP. View "In re Commitment of Jeffery Lee Stoddard" on Justia Law

In this negligence action, the Supreme Court vacated the default judgment entered by the trial court in favor of Plaintiff after Defendants failed timely to file an answer or otherwise appear, holding that the substitute service in this case did not strictly comply with the order permitting such service.More than thirty days after the trial court's default judgment entry, Defendants filed a restricted appeal asserting that Plaintiff had failed properly to serve them with process. The court of appeals affirmed, holding that a discrepancy between the address at which the trial court authorized substitute service and the address where the process server actually sent substitute service did not invalidate service or the default judgment. The Supreme Court vacated the default judgment, holding that substitute service did not strictly comply with the trial court's order. View "Spanton v. Bellah" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the trial court's grant of summary judgment for Defendants in this breach of contract and fiduciary duty action, holding that the court of appeals erred in finding that Defendants failed properly to authenticate uncertified copies of a prior jury verdict and judgment - documents upon which the motion for summary judgment relied.Approximately four thousand plaintiffs sued their former attorney and his law firm, alleging breach of contractual and fiduciary duties. The trial court granted summary judgment in favor of Defendants. The court of appeals reversed, concluding that the documents at issue were not properly authenticated and thus were not competent summary judgment evidence. The Supreme Court reversed, holding that the trial court properly exercised its discretion by finding the documents authentic and competent as summary judgment evidence. View "Fleming v. Wilson" on Justia Law

In this cattle-feeding dispute, the Supreme Court affirmed the judgment of the court of appeals overturning the trial court's denial of Appellees' post-judgment motion to compel arbitration, holding that a party does not forfeit its right to challenge a ruling on appeal from a final judgment simply by choosing not to pursue an interlocutory appeal of that ruling.Appellants brought this action alleging fraud, unjust enrichment, and other claims. Appellees moved to dismiss the suit and compel arbitration, arguing that the claims were subject to the agreement's arbitration clause. The trial court denied the motion, and Appellees did not challenge the court's ruling through an interlocutory appeal. After the trial court rendered judgment Appellees appealed, arguing that the trial court erred when it denied their motion to compel arbitration. The court of appeals reversed and remanded with instructions that the trial court order the parties to arbitration. The Supreme Court affirmed, holding (1) the court of appeals had jurisdiction to consider the trial court's denial of Appellees' motion to compel arbitration; and (2) on the merits, the court of appeals did not err in ordering arbitration. View "Bonsmara Natural Beef Co. v. Hart of Texas Cattle Feeders, LLC" on Justia Law