Justia Texas Supreme Court Opinion Summaries

Juvenile was charged with attempted capital murder, aggravated assault on a public servant, and deadly conduct. The jury adjudicated Juvenile of aggravated assault and deadly conduct, assessing determinate sentences for forty years and ten years, respectively. The court of appeals affirmed the aggravated assault adjudication but reversed on deadly conduct, concluding that the trial court committed reversible error by submitting elements of the offense to the jury disjunctively, allowing for a non-uanimous verdict. The State appealed. The Supreme Court reversed, holding that the trial court's disjunctive jury instruction, given without objection, was not reversible error, as the harm to Juvenile, given the jury's other findings and the evidence, was only theoretical, not actual. View "In re L.D.C." on Justia Law

This case involved an inverse-condemnation dispute over ten acres. At issue was who had title to the parcel: the Texas Department of Transportation (TxDOT), the City of Edinburg (City), or API Pipe Supply and Paisano Service Company (collectively, API). In 2003, the trial court awarded the City a "fee title" to the property subject to a drainage easement granted to TxDOT. In 2004, the trial court entered a judgment purporting to render the 2003 judgment null and void. API claimed the judgment gave API fee-simple ownership, subject to a drainage easement granted to the City, and, via subsequent conveyance, to TxDOT. In 2005, TxDOT began its drainage project. API, relying on the 2004 judgment, brought a takings claim for the value of the removed soil. The trial court held in favor of API, and the court of appeals affirmed. The Supreme Court reversed and dismissed the suit, holding (1) the 2004 judgment was void and therefore could not supersede the valid 2003 judgment; (2) API was statutorily ineligible for "innocent purchaser" status, and equitable estoppel was inapplicable against the government in this case; and (3) because API held no interest in the land, API's takings claim failed. View "Dep't of Transp. v. A.P.I. Pipe & Supply, LLC" on Justia Law

Landowner purchased property for the purpose of developing the land, obtained permits, and filled a portion of the property to the 100-year flood level. The municipality subsequently constructed a facility partly on the property that would detain storm water on the property in a significant flood, thus causing the property again to be below the 100-year flood level and undevelopable without additional fill. Landowner sought damages under statutory and inverse condemnation theories. The trial court ruled in favor of Landowner and awarded damages of $694,600. The court of appeals reversed as to the inverse condemnation claim, holding the claim was premature because the property had not yet flooded. The Supreme Court reversed, holding that the claim was not premature because Landowner's claim was for the present inability to develop the property as previously approved unless the property was filled. Remanded. View "Kopplow Dev., Inc. v. City of San Antonio" on Justia Law

The State brought an action for forfeiture of a vehicle and $90,235 found in it following a traffic stop, alleging that the property was contraband. The driver of the vehicle (Driver) answered the suit, asserting that he owned the property and requesting dismissal of the forfeiture action. The trial court granted summary judgment in favor of Driver. The court of appeals affirmed, holding that the State failed to present sufficient evidence that a substantial connection existed between the property and illegal drug dealing activities. The Supreme Court reversed, holding (1) the determination of whether law enforcement officers had probable cause to seize the property, that is, a reasonable belief in a substantial connection between the property and illegal activities, must be assessed in light of the facts as the seizing officers reasonably believed them to be; and (2) Driver did not conclusively negate such a belief. Remanded. View "States v. Ninety Thousand Two Hundred Thirty-Five Dollars" on Justia Law

A school district (District) obtained an in rem delinquent property tax judgment against an oil and gas lease that Respondent owned and operated. Respondent did not appeal, and the District foreclosed its judgment lien on the leasehold, taking ownership. The Railroad Commission ordered Respondent to plug a well on the lease. Respondent did not comply, and the Commission plugged the well and brought an enforcement action in court to recover the costs of the operation and the penalty. Respondent and the Commission settled. Respondent then sued the District, alleging in part that the District's actions had resulted in a taking of his property requiring compensation. The trial court dismissed Respondent's action for want of jurisdiction, but the court of appeals reversed and remanded with respect to the takings claim. The Supreme Court reversed and dismissed the case, holding that the trial court correctly dismissed Respondent's case, as Respondent did not assert on appeal that the District took his property without compensation. View "W. Hardin County Consol. Indep. Sch. Dist. v. Poole" on Justia Law

The Texas Department of Criminal Justice Community Justice Assistance Division (TDCJ) brought this interlocutory appeal from the denial of its plea to the jurisdiction as to claims for damages related to actions of two county substance abuse treatment facility officers. The Supreme Court reversed and rendered judgment dismissing the claims against TDCJ for want of jurisdiction, holding (1) the claims against TDCJ based on the use of tangible property involved intent to accomplish intentional torts, and its plea to the jurisdiction as to those claims should have been granted; and (2) TDCJ's plea as to the remaining claims also should have been granted because there was no allegation that those claims resulted from the use of tangible property. View "Tex. Dep't of Criminal Justice v. Campos" on Justia Law

Since first imposing a franchise tax in 1893, the Legislature restructured it several times, drawing various distinctions among taxpayers with adjustments, deductions, and exemptions that became elaborate. Petitioner in this original proceeding contended that the franchise tax bore no reasonable relationship to its object, the value of the privilege of doing business in Texas, and therefore it violated the Texas Constitution's mandate that "taxation shall be equal and uniform," the Fourteenth Amendment's equal protection and due process guarantees, and the U.S. Constitution's Commerce Clause. The Supreme Court denied the petition, holding (1) Petitioner failed to establish that the franchise tax violates the Equal and Uniform Clause; (2) the failure of Petitioner's challenge based on the Equal and Uniform Clause foreclosed its equal protection challenge; (3) the franchise tax does not violate due process; and (4) the manufacturing rate does not discriminate against interstate commerce and is fairly related to the services provided by Texas. View "In re Nestle USA, Inc." on Justia Law

This case involved a dispute over the fair market value of acreage on which a gas processing facility was located. At issue was whether the trial court abused its discretion by admitting an expert's testimony that allegedly violated the value-to-the-taker rule, which prohibits measuring land's value by its unique value to a condemnor in determining a landowner's compensation. The court of appeals concluded that the trial court did not abuse its discretion. The Supreme Court reversed, holding that the expert's testimony violated the rule because it impermissibly focused on the condemnor's interest in retaining the property and was therefore inadmissible. Remanded. View "Enbridge Pipelines L.P. v. Avinger Timber, LLC" on Justia Law

The City notified a building owner that her property was in disrepair and that, unless she repaired it, the City might demolish it. After the owner failed to remedy the problem, the City declared the property a public nuisance and condemned it. Rather than appeal the nuisance determination, the property owner asserted a takings claim after the demolition. The City field an immunity-based plea to the jurisdiction, which the trial court granted. The court of appeals reversed in part, holding that the administrative-level decision to demolish the owner's property did not preclude her from seeking a de novo review of that decision in a constitutional suit. The Supreme Court reversed in part and rendered judgment dismissing the owner's claims, holding that because the owner never appealed her nuisance determination, her takings claims were barred, and the trial court correctly dismissed them. View "City of Beaumont v. Como" on Justia Law

Respondent, a professor at Prairie View A&M University, filed a complaint with the EEOC and the Texas Workforce Commission civil rights division (TWC), alleging race and nationality-based pay discrimination, about two years after her promotion to full professor. Respondent subsequently filed suit against the University in state court under the Texas Commission on Human Rights Act (TCHRA). The University filed a plea to the jurisdiction, asserting Respondent's complaint was untimely filed pursuant to the 180-day limitations period under the TCHRA. The trial court denied the University's plea. The court of appeals affirmed, holding that the federal Ledbetter Act, which provides that the limitations period begins anew each time a claimant receives a paycheck containing a discriminatory amount, applies to claims brought under the TCHRA, and Respondent's claim was therefore timely because she received a paycheck containing an alleged discriminatory amount within 180 days of the date she filed her complain with the TWC. The Supreme Court reversed, holding (1) the Ledbetter Act does not apply to a claim brought under the TCHRA; and (2) because Respondent failed to timely file her complaint with the TWC, her suit was jurisdictionally barred. View "Prairie View A&M Univ. v. Chatha " on Justia Law