Justia Texas Supreme Court Opinion Summaries

The Supreme Court of Texas reviewed a case involving the State of Texas, Ken Paxton in his official capacity as Attorney General of Texas, the Texas Medical Board, and Stephen Brint Carlton in his official capacity as Executive Director of the Texas Medical Board (collectively, the State) against a group of women and physicians. The plaintiffs challenged the constitutionality of Texas's abortion laws, specifically the Human Life Protection Act, which generally prohibits performing an abortion except when a pregnant woman has a life-threatening physical condition that poses a risk of death or serious physical impairment unless an abortion is performed.The case reached the Supreme Court of Texas as a direct appeal from a temporary injunction issued by the 353rd District Court, Travis County, Texas, which halted the enforcement of Texas's abortion laws in various circumstances. The State contested the injunction, arguing that the plaintiffs lacked standing, the State had sovereign immunity, and the current Texas law permitting life-saving abortion was not more limiting than the Texas Constitution permits.The Supreme Court of Texas held that one of the plaintiffs, Dr. Damla Karsan, had standing to challenge the Attorney General’s enforcement of the Human Life Protection Act against her. The court also concluded that the Declaratory Judgments Act waives the State’s immunity for a claim that a statute violates the state constitution. The court further clarified that under the Human Life Protection Act, a woman with a life-threatening physical condition and her physician have the legal authority to proceed with an abortion to save the woman’s life or major bodily function, in the exercise of reasonable medical judgment and with the woman’s informed consent. The court concluded that Dr. Karsan had not demonstrated that the part of the Human Life Protection Act that permits life-saving abortion is narrower than the Texas Constitution allows. As a result, the court vacated the lower court's injunction order. View "State v. Zurawski" on Justia Law

In 2020, Luke Hogan, a graduate student at Southern Methodist University (SMU), found his final semester disrupted by the COVID-19 pandemic. Like many institutions, SMU shifted to online classes in response to government lockdown orders. Hogan, feeling cheated out of the in-person educational experience he had paid for, sued SMU for breach of contract. He sought a refund of his tuition and fees, arguing that the shift to online learning constituted a breach of SMU's promise of in-person education.The federal district court sided with SMU, and Hogan appealed. The Fifth Circuit then certified a question to the Supreme Court of Texas: Does the application of the Pandemic Liability Protection Act (PLPA) to Hogan’s breach-of-contract claim violate the retroactivity clause in article I, section 16 of the Texas Constitution? The PLPA, enacted in 2021, protects schools from monetary liability for altering their activities in response to the pandemic.The Supreme Court of Texas held that the application of the PLPA to Hogan's claim does not violate the Texas Constitution's prohibition on retroactive laws. The court reasoned that Hogan did not have a settled expectation of recovering damages from SMU under these circumstances. The court noted that the common law has traditionally excused a party from performing a contract when performance is rendered impossible by an act of God or government. The court also pointed out that Hogan voluntarily accepted SMU's offer to complete his degree online without a corresponding offer of tuition refunds or reduced fees. Therefore, any right of recovery that might have existed for Hogan was speculative and untested prior to the PLPA's enactment. The court concluded that the PLPA, enacted to resolve legal uncertainty created by the pandemic, did not upset Hogan's settled expectations and thus did not violate the constitutional prohibition on retroactive laws. View "HOGAN v. SOUTHERN METHODIST UNIVERSITY" on Justia Law

The case involves successors in interest of mineral-rights holders who sued in 2019 to declare a 1999 judgment foreclosing on their predecessors’ property for delinquent taxes as void. They argued that there was constitutionally inadequate notice of the foreclosure suit, rendering the foreclosure judgment and the tax sale that followed both void. The current owners sought traditional summary judgment based on the Tax Code’s command that an action relating to the title to property against the purchaser of the property at a tax sale may not be commenced later than one year after the date that the deed executed to the purchaser at the tax sale is filed of record.The trial court granted the current owners' motion for summary judgment, and the court of appeals affirmed. The majority held that the sheriff’s deed conclusively established the accrual date for limitations, so the burden shifted to the successors to adduce evidence raising a genuine issue of material fact as to whether there was a due-process violation that could render the statute of limitations inoperable. Because the successors relied only on their arguments and presented no evidence of a due-process violation, the majority concluded, the current owners were entitled to summary judgment.The Supreme Court of Texas held that under Draughon v. Johnson, the nonmovant seeking to avoid the limitations bar by raising a due-process challenge bears the burden to adduce evidence raising a genuine issue of material fact about whether the underlying judgment is actually void for lack of due process. Because the nonmovant here adduced no such evidence, the trial court correctly granted summary judgment based on Section 33.54(a)(1). However, the court also noted that the law governing this case has undergone meaningful refinement since the summary-judgment proceedings took place. Given these recent and substantial developments in the relevant law, the court remanded this case to the trial court for further proceedings in the interest of justice. View "GILL v. HILL" on Justia Law

The case before the Supreme Court of Texas concerned the City of Dallas and the Employees’ Retirement Fund of the City of Dallas. The issue at hand was whether a city ordinance could confer a third party the perpetual right to veto categories of future lawmaking. The Court of Appeals held that the City of Dallas could not amend Chapter 40A of its code of ordinances unless the board of trustees of the Employees’ Retirement Fund agreed to the amendment. However, the Supreme Court of Texas found that such delegation of lawmaking authority was not permissible.The Supreme Court of Texas based its ruling on the principle that a legislative body cannot bind its successors, and on the constitutional principle forbidding the city council from giving away its authority to legislate. The court determined that the board’s veto in § 40A-35(a) was unenforceable and cannot prevent an otherwise valid ordinance from taking effect.However, the court did not resolve whether the City must hold an election that submits § 8-1.5(a-1) to the voters before it can enforce that provision. The court declined to address this question and remanded the case back to the Court of Appeals for further consideration. View "THE CITY OF DALLAS v. THE EMPLOYEES' RETIREMENT FUND OF THE CITY OF DALLAS" on Justia Law

In this case handled by the Supreme Court of Texas, the parents of two children, Kate Cox and Justin Cox, along with their doctor, Dr. Damla Karsan, filed a suit to challenge the enforcement of Texas laws that prohibit abortion. Mrs. Cox was about 20 weeks pregnant with a baby diagnosed with trisomy 18, a serious genetic disorder. The suit sought to apply a medical-necessity exception provided in the Texas law, which allows an abortion if a woman's life is threatened or she faces a serious risk of substantial impairment of a major bodily function due to her pregnancy.The court, in its decision, clarified that the exception to the abortion prohibition is based on the reasonable medical judgment of a doctor, not a court. It was noted that Dr. Karsan presented a "good faith belief" that Mrs. Cox meets the exception's requirements but did not assert that her belief meets the objective standard of "reasonable medical judgment."The court held that judges lack the authority to broaden the statutory exception by interpreting it and held the trial court erred in applying a different, lower standard instead of requiring reasonable medical judgment. The court emphasized that the exception requires a doctor's decision whether a pregnant woman’s complications pose the required risks.The court conditionally granted relief and directed the trial court to vacate the temporary restraining order that had restrained the Attorney General from enforcing the abortion laws against Dr. Karsan and others related to the case, based solely on the verified pleading. The court also noted that nothing in their opinion prevents a physician from acting if, in that physician’s reasonable medical judgment, they determine that the pregnant woman has a life-threatening physical condition. View "IN RE STATE OF TEXAS" on Justia Law

The Supreme Court vacated the judgment of the court of appeals affirming the trial court's judgment issuing in July 2021 a temporary restraining order prohibiting enforcement of executive order GA-38, holding that this case is remanded for further proceedings consistent with this Court's opinion in Abbott v. Harris County, 22-0124, which concerned the scope and constitutionality of the Governor's authority under the Disaster Act to prohibit local governments from imposing mask requirements.The City of San Antonio and Bexar County jointly filed this lawsuit challenging GA-38, which prohibited local officials from requiring masks in response to the coronavirus epidemic. The district court issued a temporary restraining order prohibiting enforcement of the executive order and then temporarily enjoined the Governor and others from enforcing GA-38 to the extent that such a requirement would interfere with the local official's authority to require masks in government-owed buildings and schools. The court of appeals affirmed the temporary injunction. In light of this Court's decision in Abbott v. Harris County, the Supreme Court vacated the judgment below, holding that remand was required. View "Abbott v. City of San Antonio" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals in this products-liability case concluding that the exercise of personal jurisdiction over Defendants was consistent with due process, holding that the minimum-contacts analysis requires evaluation of a defendant's contacts with the forum - Texas - as a whole.Plaintiff was injured when he used a lithium-ion battery that he bought at a store in Texas and used it to charge his e-cigarette. Although Defendants sold and distributed the batteries to manufacturers in Texas they argued that Texas courts lacked personal jurisdiction because they did not send the batteries to Texas for resale to individual consumers to use with e-cigarettes. Specifically, Defendants argued that Plaintiff's claims arose out of the use of the battery in a way Defendants never intended by an individual consumer they never targeted. The lower courts concluded that the exercise of personal jurisdiction over Defendants was consistent with due process. The Supreme Court affirmed, holding that the relatedness prong of the minimum-contacts analysis does not require that the plaintiff's claims arose out of a set of facts mirroring the defendant's expectations about the course its product would follow after entering the state of Texas. View "LG Chem America, Inc. v. Morgan" on Justia Law

The Supreme Court reversed the judgment of the court of appeals on a survival claim brought by the estate of Clark Davis against United Rentals North America, Inc., rendered a take nothing judgment on this claim, and remanded the case to the district court for a new trial on the remaining claims, holding that racial considerations impermissibly tainted the selection of the jury in the underlying trial.During jury selection, Plaintiffs' counsel stated that "the African-American female was the most favorable juror in this case," and this announced preference was consistent with Plaintiffs' peremptory strikes. The jury returned a verdict for Plaintiffs, and the district court awarded $5 million to Davis's estate. The court of appeals affirmed. The Supreme Court reversed, holding that a new trial was required because counsel stated a racial preference in jury selection, the peremptory strikes were consistent with that preference, and the district court did not remedy the issue. View "United Rentals North America, Inc. v. Evans" on Justia Law

In this "highly unusual" personal jurisdiction dispute the Supreme Court held that Texas courts have specific jurisdiction over German automobile manufacturers based on their intentional post-sale tampering with affected vehicles that were owned, operated, and serviced in Texas.The State and several local governments brought civil actions to enforce state environmental laws against Defendants - German automobile manufacturers that intentionally evaded federal emissions standards by embedding illegal emissions-defeating technology in graded vehicles. At issue was whether the manufacturers' contacts with Texas satisfied the constitutional requisites to exercising specific personal jurisdiction. The trial court ruled that the manufacturers were amenable to specific personal jurisdiction in Texas, but the court of appeals reversed. The Supreme Court reversed, holding that where the manufacturers developed the product, controlled the distribution stream that brought the product to Texas, and "called all the shots," the trial court did not err in exercising specific personal jurisdiction over the German manufacturers. View "State v. Volkswagen Aktiengesellschaft" on Justia Law

The Supreme Court held that a claimant alleging wrongful imprisonment against state government entities and employees may not maintain such a suit once the claimant has received Tim Cole Act compensation through the state administrative process.Plaintiff was imprisoned for about twelve years, most of them on death row, until his conviction was vacated on the ground that the prosecutor had failed to disclose exculpatory evidence during his criminal trial. Plaintiff brought suit in federal court under 42 U.S.C. 1983, alleging that various state government entities and employees had violated his constitutional rights. Based on the results of an independent investigation, the district court dismissed Plaintiff's charges on the grounds that Plaintiff was actually innocent. Plaintiff was subsequently granted compensation under the Tim Cole Act. The district court granted Defendants' motion to dismiss Plaintiff's federal case, concluding that Plaintiff's recent of compensation from the state foreclosed his suit. On appeal, the federal district court certified a question to the Supreme Court. The Supreme Court answered that Plaintiff's acceptance of the Tim Cole Act compensation barred maintenance of this lawsuit. View "Brown v. City of Houston, Texas" on Justia Law