Justia Texas Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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Petitioners and its affiliates, manufacturers and distributors of food and beverages in the United States, sought a declaration that the Texas franchise tax was unconstitutional, Tex. Tax Code 171.0001-.501, an injunction prohibiting its collection, and mandamus relief compelling the Comptroller to refund the taxes they paid from 2009 through 2011. Petitioners did not pay their taxes under protest or request a refund from the Comptroller, statutory requisites to taxpayers suits in the district court but not, relators contended, for suit in this court. The court disagreed and held that the statutory requisites were conditions on the legislative waiver of the State's immunity from suit. Accordingly, the court dismissed the case for want of jurisdiction. View "In re Nestle USA, Inc., Switchplace, LLC, and NSBMA, LP, Relators" on Justia Law

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Respondent appealed the URSB's determination that her property was an urban nuisance and that the property should be demolished. The trial court affirmed the USRB's finding that respondent's home was an urban nuisance and awarded the city attorneys fees. The trial court then severed respondent's constitutional claims and tried them to a jury. At the close of trial, the City moved unsuccessfully for a directed verdict on the grounds that the Board's nuisance determination was res judicata, precluding respondent's takings claim. The jury rejected the City's contention that respondent's home was a public nuisance and awarded her for the destruction of her house. The trial court denied the City's post-verdict motions and signed a judgment in conformance with the verdict. The court of appeals affirmed but held that the USRB's nuisance finding could not be preclusive because of the brief delay between the nuisance finding and the house's demolition. The City subsequently petitioned the court for review, arguing that the lower courts erred in failing to give the URSB's nuisance determination preclusive effect in respondent's taking claim. The court held that the determination was not preclusive because substantial evidence review of nuisance determination resulting in a home's demolition did not sufficiently protect a person's rights under Article I, Section 17 of the Texas Constitution. View "City of Dallas v. Stewart" on Justia Law

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A property owner appealed an administrative determination that his property was a nuisance and he also asserted a takings claim. The property owner then nonsuited the case. He later filed this suit, again alleging that the government illegally took his property. Because the property owner was collaterally estopped from doing so, the court affirmed the judgment of the court of appeals. View "Patel v. City of Everman" on Justia Law

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Plaintiff sued Ryland in 2007 and the case went to trial in May 2010. On May 4th, the jury returned a verdict for plaintiff. On May 25, 2010 - after the jury verdict but before the judgment was signed - Ryland filed a JNOV motion on legal insufficiency grounds. Though not styled as a motion for new trial, the JNOV motion also requested a new trial in the alternative. Prior to holding a hearing on the JNOV motion, the trial court signed a judgment for plaintiff on June 14, 2010, initiating the appellate time table. The judgment also purported to deny Ryland's JNOV motion. The court held that because an arguable interpretation of the procedural rules allowed Ryland's premature, JNOV motion to extend the appellate timetable to 90 days, the court of appeals erred in dismissing the appeal. Accordingly, pursuant to Texas Rule of Appellate Procedure 59.1 without hearing oral argument, the court reversed the court of appeals' judgment and remanded the case to that court. View "Ryland Enterprise, Inc. v. Weatherspoon" on Justia Law

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This case arose out of patent infringement litigation. At issue was whether federal courts possess exclusive subject matter jurisdiction over state-based legal malpractice claims that require the application of patent law. The federal patent issue presented here was necessary, disputed, and substantial within the context of the overlying state legal malpractice lawsuit. Additionally, the patent issue could be determined without creating a jurisdictional imbalance between state and federal courts. Therefore, the court concluded that exclusive federal jurisdiction existed in this case. Accordingly, without reaching the merits of the legal malpractice claim, the court reversed the court of appeals' judgment and dismissed this case. View "Minton v. Gunn, et al." on Justia Law

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Respondent appealed the Dallas Urban Rehabilitation Standards Board's decision that her house was a nuisance and order of demolition, alleging a due process claim and a claim for an unconstitutional taking. The trial court, on substantial evidence review, affirmed the Board's findings. The court of appeals affirmed but held that the Board's nuisance finding could not be preclusive because of the brief delay between the nuisance finding and the house's demolition. The city petitioned the court for review, arguing that the lower courts erred in failing to give the Board's nuisance determination preclusive effect in respondent's taking claim. The court held that a system that permitted constitutional issues of this importance to be decided by an administrative board, whose decisions were essentially conclusive, did not correctly balance the need to abate nuisances against the rights accorded to property owners under the Texas Constitution. Accordingly, independent court review was a necessity and affirmed the court of appeals but on different grounds. View "City of Dallas v. Stewart" on Justia Law

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Voters sued the Secretary of State arguing that her certification of the eSlate, a paperless direct recording electronic machine, violated the Election Code and the Texas Constitution. At issue was whether voters had standing to pursue complaints about an electronic voting machine that did not produce a contemporaneous paper record of each vote. The court held that because it concluded that most of the voters allegations involved generalized grievances about the lawfulness of government acts, and because their remaining claims failed on their merits, the court reversed the judgment of the court of appeals and rendered judgment dismissing the case. View "Andrade v. NAACP, et al." on Justia Law

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The City of Dallas seized vehicles, which it alleged were stolen, from a company that was entitled to petition for their return. Instead of pursuing its statutory remedy, the company sued, alleging that its interest in those vehicles had been taken without just compensation. The court held that because the company had actual knowledge of the vehicles seizure the company knew the cars were seized from its lots, and it knew who seized them, it was required to pursue a chapter 47 proceeding. Accordingly, the court held that the availability of the statutory remedy precluded a takings claims and reversed the court of appeals judgment and rendered judgment dismissing the suit. View "City of Dallas v. VSC, LLC" on Justia Law

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This action arose out of condemnation proceedings initiated by the State after the landowners and the State could not agree on the amount of compensation for a .33 acres out of a 3.5 acre tract of land fronting U.S. Highway 290 in Travis County. At issue was whether the trial court erred by only charging the jury to find the pre-taking value of the tract when there was evidence the taking did not cause damage to the remainder and whether there was any evidence the remainder suffered compensable damages. The court concluded that the trial court committed charge error by inquiring whether the landowner suffered damages to the remainder. The court also held that there was no evidence the taking caused compensable damages to the remainder and based on the jury findings, the value of the tract taken could be determined. Accordingly, the court reversed the court of appeals judgment and remanded to the trial court for rendition of judgment. View "State v. Petropoulos" on Justia Law

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Relator was held in contempt of court and confined for perjuring himself during a deposition. At issue was whether a trial court could hold a litigant in contempt for perjury committed during a deposition and whether the court should exercise mandamus jurisdiction to provide a forum for a civil litigant who was deprived of liberty pursuant to a court's contempt order, and the Court of Criminal Appeals had declined to exercise its habeas jurisdiction. The court held that the trial court abused its discretion where such perjury did not obstruct the operation of the court. The court also held that relator had no adequate remedy by appeal where the underlying suit was civil in nature and the Court of Appeals declined to grant relator leave to file a habeas petition in that court. Accordingly, mandamus was the appropriate remedy to correct the trial court's abuse of discretion and the court conditionally granted relief.