Justia Texas Supreme Court Opinion Summaries

A jury found petitioner committed sexual assault of a child based on the testimony of two witnesses who have recanted, and sentenced petitioner to 22 years' confinement after hearing false testimony by a State's expert. The district court denied habeas relief, the court of appeals affirmed, and petitioner subsequently appealed. The court concluded that petitioner was not entitled to relief on his claims of actual innocence or ineffective assistance of counsel. The court concluded, however, that false testimony by the State's expert witness contributed to his sentence and he was therefore entitled to a new disposition hearing. View "In the matter of M.P.A." on Justia Law

Relator sought compensation from the state following the Texas Court of Appeals' grant of habeas relief. Under the Tim Cole Act, Tex. Civ. Prac. & Rem. Code 103.001(a), a wrongfully imprisoned person could seek compensation from the state for the period of wrongful imprisonment. The court conditionally granted the petition for mandamus and instructed the Comptroller to comply and compensate relator under the terms of the Act where the Court of Criminal Appeals granted habeas relief on a Schlup v. Delo claim and relator's order clearly indicated that relief was based on actual innocence. View "In re Allen" on Justia Law

This case arose when respondent was arrested by a state trooper for driving while intoxicated. At issue was whether a peace officer's arrest report must be excluded from evidence if not sworn as required by law. Because it was no less a criminal offense to make a false statement in a governmental record than it was to make one under oath, the court held that an officer's failure to swear to a report did not deprive it of the assurance of veracity or render it inadmissible. Consequently, the court reversed the court of appeals' judgment and remanded. View "Texas Dept. of Public Safety v. Caruana" on Justia Law

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

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

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

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

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

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

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