Justia Texas Supreme Court Opinion Summaries

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

The Supreme Court reversed the order of the trial court dismissing the claims brought by the Mexican American Legislative Caucus (MALC) and the claim brought by a group of plaintiffs referred to as the Gutierrez Plaintiffs that the recently enacted laws reapportioning Texas's legislative districts violate Tex. Const. art. III, 26, holding that the trial court erred in part.MALC and the Gutierrez Plaintiffs sued Defendants - various State officials - claiming that the laws at issue violated Article III, Sections 26 and 28. Defendants filed pleas to the jurisdiction, which the trial court largely denied. The Supreme Court reversed in part and remanded the case to the trial court, holding (1) MALC lacked associational standing to pursue its claims; (2) at least one of the Gutierrez Plaintiffs had standing to pursue each claim a proper defendant, but not the State; (3) the Gutierrez Plaintiffs' section 26 was not barred by sovereign immunity, but the section 28 claim was; and (4) the Gutierrez Plaintiffs should have the opportunity to replead their section 26 claim against a proper defendant. View "Abbott v. Mexican American Legislative Caucus" on Justia Law

The Supreme Court reversed the judgment of the trial court permanently enjoining the Texas Department of State Health Services from enforcing a new Texas law that prohibited the processing and manufacturing of smokable hemp products, holding that Plaintiffs were not entitled to relief.In their complaint, Plaintiffs - Texas-based entities that manufacture, process, distribute, and sell hemp products - argued that Tex. Const. art. I, 19 invalidated the challenged law and sought an injunction prohibiting Defendant from enforcing the law. The trial court declared that Tex. Health & Safety Code 443.202(4) violated the Texas Constitution and that 25 Tex. Admin. Code 300.104 was invalid in its entirety and enjoined Defendant from enforcing the statute or the rule. The Supreme Court reversed, holding that Plaintiffs' complaints did not assert the deprivation of an interest substantively protected by the Texas Constitution's due course clause. View "Texas Department of State Health Services v. Crown Distributing LLC" on Justia Law

The Supreme Court held that the application the Fair Practices of Equipment Manufacturers, Distributors, Wholesalers, and Dealers Act, Tex. Bus. & Com. Code 57.001-.402, in this case did not violate the constitutional prohibition against retroactive laws in Tex. Const. art. I, 16.In the 1990s, Fire Protection Service, Inc. (FPS), orally agreed to be an authorized dealer and servicer of the life rafts manufactured by Survitec Survival Products, Inc. Nearly six years after the promulgation of the Act, which prohibits a supplier from terminating a dealer agreement without good cause, Survitec notified FPS that it was terminating their relationship. FPS sued for a violation of the Act. The district court entered judgment for Survitec. On appeal, the Fifth Circuit certified a question to the Supreme Court. The Supreme Court answered that the application of the Act to the parties' agreement does not violate the retroactivity clause in article I, section 16. View "Fire Protection Service, Inc. v. Survitec Survival Products, Inc." on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the judgment of the trial court against Landlord and in favor of the City of Baytown in this dispute over unpaid utility bills, holding that Landlord's challenge to the City's enforcement action failed to show the intentional taking or damage for public use necessary to establish a constitutional right to compensation.In this action, Landlord alleging that the City's withholding of utility service to collect payment resulted in the loss of a tenant and the disrepair of his property and was a taking in violation of the state or federal constitution. The trial court concluded that Landlord did not establish an intentional taking of private property for public use. The court of appeals reversed. The Supreme Court reversed, holding that the City's utility enforcement actions did not establish a regulatory taking of private property as a matter of law. View "City of Baytown v. Schrock" on Justia Law

The Supreme Court accepted a certified question from the United States Court of Appeals for the Fifth Circuit by answering that Texas law does not authorize certain state officials to directly or indirectly enforce the state's new abortion restriction requirements.Plaintiffs, who provided and funded abortions and support for women who obtain them in Texas, requested a declaration that Senate Bill 8, the "Texas Heartbeat Act," Tex. Health & Safety Code 171.201-.212, unconstitutionally restricted their rights and injunction prohibiting Defendants, state agency executives, from enforcing the Act's requirements. After a remand, the Fifth Circuit certified a question to the Supreme Court. The Supreme Court answered answered that Texas law does not grant the state agency executives named as defendants any authority to enforce the Act's requirements, either directly or indirectly. View "Whole Woman's Health v. Jackson" on Justia Law

The Supreme Court conditionally granted Petitioner's petition for a writ of mandamus and directed the district court to rescind a temporary restraining order (TRO) issued by the district court prohibiting the Governor and the Speaker of the House (Defendants) from compelling the attendance of members of the Texas House of Representatives (Plaintiffs), holding that the Texas Constitution gives the House of Representatives the authority to physically compel the attendance of absent members.Plaintiffs fled the state on July 12, 2021 in order to deny the House a quorum, thus preventing the legislature, in special session, from enacting voting legislation they opposed. Plaintiffs fled the state to escape the jurisdiction of the House, whose rules provide that absent members may be arrested and their attendance secured and retained. Plaintiffs then brought this action seeking an injunction prohibiting their arrest. The district court granted a TRO prohibiting Defendants from compelling Plaintiffs' attendance by arrest or restraint. The Supreme Court directed the district court to rescind the TRO, holding that the district court abused its discretion by granting the TRO. View "In re Abbott" on Justia Law

In this matter concerning the general appropriations bill for the next biennium beginning September 1, 2021 the Supreme Court denied Relators' request for a writ of mandamus asserting that the Governor's veto of the Legislature's appropriation for its own operations threatened the Legislature's ability to operate and therefore violated the constitutional separation of powers, holding that this Court declines to settle a dispute between coequal branches of the government.The day before the eighty-seventh Legislature adjourned, Democratic members of the House of Representatives prevented passage of pending legislation that they had opposed by leaving the chamber. When the general appropriations bill was presented to the Governor several days later, the Governor vetoed the Legislature's appropriation for its own operations because "[f]unding should not be provided for those who quit their jobs early." In this mandamus proceeding, Relators - the House Democratic Caucus and the majority of Democratic House members - argued that the veto was an attempt to abolish the Legislature in violation of separation of powers principles. The Supreme Court denied relief, holding that this dispute was one between the members of one branch rather than one between the branches, and where the Governor has made funding for continued legislative operations through the end of September, relief in mandamus was not appropriate. View "In re Turner" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the judgment of the trial court naming Aunt and Uncle managing conservators of parents' two children, naming Mother and Father possessory conservators, and stating that, in the absence of mutual agreement, Mother could have supervised visitation with the children at the discretion of the managing conservator, holding that there was no error.In affirming, the court of appeals determined that the evidence was sufficient to support the terms of the visitation order, that the terms of the order were permissible upon a finding that they were in the best interest of the children, and denying Mother's constitutional challenge to Tex. Fam. Code 262.201(o). The Supreme Court affirmed, holding (1) because the trial court could have reasonably concluded that a restriction on Mother's right of access was in the children's best interest, there was not abuse of discretion; and (2) Mother's constitutional challenges were rendered moot by the trial court's issuance of a final order. View "In re J.J.R.S." on Justia Law