Justia Texas Supreme Court Opinion Summaries

An Oklahoma company, formed to acquire mineral rights in Appalachia, alleged that two Texas parties failed to convey certain West Virginia mineral interests as contractually agreed. The Oklahoma company, which included non-Texas owners and participants, had funded the purchase of these rights, but a number of mineral deeds were recorded in the name of the Texas seller rather than the buyer. As a result, royalties from those mineral rights were paid to the seller. The Oklahoma plaintiff sought to compel the Texas defendants to reform the deeds, perform their contractual obligations, declare the plaintiff’s entitlement to the royalties, and enjoin the defendants from transferring the disputed interests.The 141st District Court in Tarrant County, Texas, denied the defendants’ plea to the jurisdiction and ultimately granted summary judgment for the plaintiff, awarding specific performance, deed reformation, declaratory relief, an injunction, and monetary relief. The court found it had jurisdiction over the parties and the contract, even though the mineral rights were located in West Virginia. On appeal, the Court of Appeals for the Second District of Texas reversed, holding that Texas courts lacked subject-matter jurisdiction because the suit’s gravamen was the adjudication of title to foreign (West Virginia) real property.The Supreme Court of Texas reviewed the matter and disagreed with the appellate court’s application of the so-called “gist” rule. The Supreme Court held that Texas courts with personal jurisdiction over the parties may issue in personam judgments concerning contractual obligations to convey out-of-state real property, as long as the judgment binds only the parties and does not purport to establish or alter title to the property by the court’s own force. The Supreme Court reversed the appellate court’s judgment and remanded for consideration of remaining issues. View "BRAXTON MINERALS III, LLC v. BAUER" on Justia Law

The case involves disputes among the descendants of Roy and Grace Whittenburg, who were beneficiaries of separate trusts holding interests in a large ranch spanning New Mexico and Colorado. After years of litigation over the ranch’s ownership, the parties signed two settlement agreements: a Partial Settlement Agreement (PSA) and a later Compromise Settlement Agreement (CSA). These agreements were intended to resolve their disputes, with provisions for partitioning the ranch and a clause designating Texas as the forum for enforcement. When the parties could not agree on partitioning, a group led by Angela Kate initiated partition proceedings in New Mexico, as allowed by the agreements. Another group, led by John Burk, opposed the partition, resulting in protracted litigation and additional attorney’s fees.The 251st District Court of Randall County, Texas, after a bench trial, found John Burk had breached the settlement agreements by opposing the partition in the New Mexico litigation, causing Angela Kate to incur $216,112 in extra attorney’s fees. Despite these findings, the trial court entered a take-nothing judgment, holding that the attorney’s fees from the New Mexico litigation were not recoverable as damages. The Court of Appeals for the Seventh District of Texas affirmed, reasoning that the American Rule barred recovery of such fees as damages for breach of contract.The Supreme Court of Texas reversed the Court of Appeals. It held that the American Rule does not bar recovery of attorney’s fees incurred in prior litigation as damages for breach of a settlement agreement, provided the breach was not itself the basis for that prior litigation. Because the fees at issue resulted from litigation initiated before John Burk’s breach, Angela Kate was entitled to recover those excess fees as actual damages. The Court also held she could seek reasonable attorney’s fees for the Texas suit, remanding for reconsideration of the appropriate amount. View "WANG v. WHITTENBURG" on Justia Law

A company providing paratransit and microtransit services under contract with a regional public transportation authority subcontracted another company to supply vehicles and drivers. After several months, the subcontractor terminated the agreement and brought suit against the transportation company and the authority, asserting claims including breach of contract, quantum meruit, tortious interference, fraud, and negligent misrepresentation. The fraud claim centered on alleged false representations made to induce the subcontract.The trial court (Texas District Court) ruled on a motion to dismiss under Texas Rule of Civil Procedure 91a, which allows dismissal if pleadings show no legal or factual basis for relief. The court dismissed the fraud and other tort claims against all defendants, as well as the breach of contract claim against the transportation authority and its primary contractor. It limited potential contract damages as to the contractor’s subsidiary and severed and abated remaining claims. The subcontractor appealed the dismissal of its claims against the main transportation company.The Court of Appeals for the Fifth District of Texas reversed in part, finding that the breach of contract and fraud claims against the main transportation company had a basis in law and that its statutory immunity under Texas Transportation Code § 452.056(d) was not conclusively established. The Supreme Court of Texas, reviewing only the fraud claim, held that the statutory immunity did apply. Because the pleadings showed the transportation company was contractually performing the authority’s function, and the authority itself would be immune from a fraud claim (an intentional tort), the company was likewise immune from liability for fraud. Accordingly, the Supreme Court of Texas reversed the Court of Appeals’ judgment and reinstated the trial court’s dismissal of the fraud claim. The case was remanded for further proceedings on any remaining claims. View "MV TRANSPORTATION, INC. v. GDS TRANSPORT, LLC" on Justia Law

The case centers on an economic development agreement between a city and county in Texas and a private foundation, aimed at fostering the construction of a retail shopping center anchored by a Gander Mountain store. The city and county pledged portions of future sales-tax revenues to the foundation, which used the funds to secure a construction loan for the facility. The agreements required that the tax proceeds be used solely to repay the construction debt. Gander Mountain operated for eleven years before closing its store, but the shopping center continued to generate significant economic activity and tax revenue, with the former anchor tenant’s space later occupied by another retailer.After Gander Mountain’s closure in 2015, the city and county ceased payments, claiming the public purpose of the grants had ended. They sought declaratory relief in the District Court of Navarro County, arguing that continued payments would be unconstitutional under the Texas Constitution’s Gift Clauses. The district court granted summary judgment to the city and county, ruling that the closure ended the public purpose and that the agreements lacked sufficient controls to ensure public purposes were met. The Court of Appeals for the Tenth District of Texas affirmed, holding that the economic development grants remained subject to the Gift Clauses and that the agreements failed to satisfy their requirements.The Supreme Court of Texas reviewed the case and held that economic-development grants authorized by article III, section 52-a of the Texas Constitution remain subject to the Gift Clauses. The Court determined that the lower courts erred by focusing narrowly on the operation of a specific store rather than the broader public purpose of economic development. It held that the agreements likely satisfied the constitutional requirements of public purpose, consideration, and adequate controls, and that summary judgment was improper. The Supreme Court of Texas reversed the lower courts’ judgments and remanded the case for further proceedings. View "JPMORGAN CHASE BANK, N.A. v. CITY OF CORSICANA AND NAVARRO COUNTY" on Justia Law

A municipally owned utility in San Antonio owns power poles used for distributing electricity. Since 1984, a telecommunications provider (and its predecessor) has attached its equipment to these poles under a written agreement. The contract set a per-pole attachment fee, allowed for annual rate increases, and included a clause requiring both parties to comply with all applicable laws affecting their rights and obligations under the agreement. Over time, the utility charged one telecommunications provider higher rates, while continuing to invoice another provider at the original rate, resulting in a disparity in charges. After amendments to the Public Utility Regulatory Act (PURA) in 2005 prohibited discriminatory pole attachment rates and required uniform and federally capped rates, the provider paying the higher fee sued, seeking relief for breach of contract and statutory violations.The trial court, after abating proceedings while the Public Utility Commission (PUC) considered the matter, granted partial summary judgment for the utility on statutory and unjust enrichment claims, but for the provider on the breach-of-contract claim. The utility appealed. The Thirteenth Court of Appeals reversed, holding that the agreement did not incorporate new statutes into its terms, and thus the provider could not base its contract claim on the utility’s alleged statutory violations.The Supreme Court of Texas reviewed the case. It held that the parties’ contract—by its express terms—incorporated post-1984 legal changes affecting their rights and obligations, including the 2005 PURA amendments. The Court concluded that the provider could pursue its contract claim based on the utility’s alleged failure to comply with current law, including prohibitions on discriminatory and excessive pole attachment rates. The Court reversed the judgment of the court of appeals and remanded the case to the trial court for further proceedings. View "SPECTRUM GULF COAST, LLC v. CITY OF SAN ANTONIO" on Justia Law

GAC Equipment, doing business as Austin Crane Service, hired Diamond Hydraulics to repair a crane’s cylinder, which later bent during a lifting operation. Each party blamed the other: Diamond argued that improper maintenance and operation by Austin Crane caused the failure, while Austin Crane claimed Diamond’s repairs were improper and used unsuitable materials. The dispute intensified during discovery, particularly over Diamond's ability to inspect the cylinder, and both parties made late expert witness designations. As trial approached, Diamond’s designated expert, Dr. Macfarlan, left his job, moved out of state, and refused to testify. Diamond attempted to substitute another expert, Dr. Hoerner, who had participated in preparing the expert report. Austin Crane objected, and the district court denied Diamond’s request to substitute its expert and to continue the trial.The 425th Judicial District Court in Williamson County, Texas, proceeded with the trial without Diamond’s causation expert. The jury found in favor of Austin Crane on both breach of contract and breach of warranty claims. Diamond appealed, arguing that the district court abused its discretion by not allowing the late expert substitution. The Court of Appeals for the Third District of Texas affirmed the trial court’s decision.The Supreme Court of Texas reviewed the case, focusing on whether Diamond showed good cause for its late expert designation under Texas Rule of Civil Procedure 193.6. The Supreme Court held that Diamond demonstrated good cause: the unavailability of Diamond’s original expert was beyond its control, Diamond acted promptly and in good faith to substitute an expert, and the excluded testimony was critical to its case. The Supreme Court concluded that the district court abused its discretion and that disparate treatment was given to the parties’ late designations. The Supreme Court of Texas reversed the court of appeals’ judgment and remanded the case for a new trial. View "DIAMOND HYDRAULICS, INC. v. GAC EQUIPMENT, LLC" on Justia Law

Equinor contracted with Lindale to supply water for hydraulic fracturing operations in North Dakota. The agreement established that Lindale would build a pipeline to deliver water, financed by Equinor’s predecessor, who would then own the pipeline. In exchange, Lindale would serve as the exclusive supplier and pumper of water “on the Pipeline,” at below-market rates. Years later, after Equinor acquired its predecessor, technological advances enabled water delivery via lay-flat hoses, a method cheaper than using the pipeline. Equinor began purchasing water from other suppliers using this new method, rather than from Lindale.Lindale sued Equinor for breach of contract in the District Court, arguing that the exclusivity clause gave Lindale the exclusive right to supply water for all of Equinor’s fracking operations. The district court found the relevant contract provision ambiguous and submitted its interpretation to a jury. The jury found for Lindale and awarded $26 million in damages. The Texas Court of Appeals for the First District affirmed, concluding that Equinor had breached the contract and that the damages award was not excessive.The Supreme Court of Texas reviewed the case and determined that the contract was unambiguous. The court interpreted the exclusivity clause to apply solely to water supplied “on the Pipeline,” as defined by the contract, and not to all water delivered to Equinor’s wells by other means. As a result, Equinor’s purchase of water from other suppliers for wells not “on the Pipeline” did not breach the contract. The court reversed the judgment of the court of appeals and rendered judgment for Equinor, holding that there was no breach as a matter of law. View "EQUINOR ENERGY LP v. LINDALE PIPELINE, LLC" on Justia Law

A group of workers was injured in a workplace accident at a South Texas refinery when a fire-suppression system, supplied and programmed by Scallon Controls, Inc., unexpectedly discharged after losing power. The workers sued S&B Engineers & Constructors, Ltd. and Sunoco Logistics Partners, the companies responsible for the project. S&B and Sunoco then brought third-party claims against Scallon, alleging breach of contract and seeking indemnification under their agreement, which included a proportional indemnity provision. Following four years of litigation, S&B and Sunoco settled with the injured workers, fully resolving the tort claims. S&B and its insurer, Zurich American Insurance Company, subsequently sought to recover from Scallon a proportional share of the settlement, corresponding to Scallon’s alleged share of fault.The trial court granted summary judgment for Scallon, and the Court of Appeals for the Ninth District of Texas affirmed, relying on prior Supreme Court of Texas decisions, notably Beech Aircraft Corp. v. Jinkins and Ethyl Corp. v. Daniel Construction Co. The appellate court held that S&B and Zurich could not maintain an indemnity claim after settling, and that Zurich’s claim was time-barred.The Supreme Court of Texas reversed, holding that neither Jinkins nor Ethyl precludes enforcement of a freely negotiated, proportional indemnification agreement after settlement. The Court clarified that such contracts are distinct from common law or statutory contribution rights and that parties may contract for comparative indemnity, so long as the contract does not require indemnification for the indemnitee’s own negligence unless stated with specific language. The Court also held that Zurich’s claim was timely, as the limitations period began to run at settlement. The case was remanded to the trial court to determine whether S&B and Zurich can establish Scallon’s proportional liability and the reasonableness of the settlement. View "S&B ENGINEERS & CONSTRUCTORS, LTD. v. SCALLON CONTROLS, INC." on Justia Law

Following Hurricane Laura, a Texas-based company, Top Notch Movers, provided moving services in Alabama and Louisiana to Shamrock Enterprises, an Alabama-based LLC. Top Notch sent a demand letter to Shamrock seeking payment for over $170,000 in unpaid invoices. Subsequently, Top Notch filed suit in Texas for nonpayment, listing Shamrock’s principal office as a Foley, Alabama address and seeking substituted service via the Texas Secretary of State under section 5.251(1)(A) of the Texas Business Organizations Code. The Secretary of State attempted to forward process to the Foley address, but the mailing was returned as undeliverable. Shamrock did not appear, and Top Notch obtained a default judgment, which was also mailed to the same address and returned.Shamrock later initiated a restricted appeal, arguing that service of process was improper. The Court of Appeals for the Thirteenth District of Texas affirmed the default judgment, finding that Shamrock was amenable to substituted service under the cited statute and that the Secretary of State’s Whitney certificate constituted irrebuttable proof of proper service.The Supreme Court of Texas reviewed the case and determined that even if Shamrock was subject to substituted service under section 5.251(1)(A), the record did not show that process was forwarded to the statutorily required address—Shamrock’s “most recent address . . . on file with the secretary of state.” The court clarified that a Whitney certificate only proves that process was sent to the address provided, not that the statutory requirements were met, and strict compliance is necessary for a valid default judgment. Therefore, the Supreme Court of Texas reversed the judgment of the Court of Appeals, vacated the default judgment, and remanded the case to the trial court for further proceedings. View "SHAMROCK ENTERPRISES, LLC v. TOP NOTCH MOVERS, LLC" on Justia Law

A Maryland real estate investment trust with over 12,000 shareholders entered into an advisory agreement with UMTH General Services, L.P. and its affiliates to manage the trust’s investments and operations. The agreement stated that the advisor was in a fiduciary relationship with the trust and its shareholders, but individual shareholders were not parties to the agreement. After allegations of mismanagement and improper advancement of legal fees surfaced, a shareholder, Nexpoint Diversified Real Estate Trust, sued derivatively in Maryland. The Maryland court dismissed the claims for lack of standing and subject matter jurisdiction. Nexpoint then transferred its shares to a subsidiary, which, along with Nexpoint, sued the advisors directly in Texas, alleging corporate waste and mismanagement, and claimed the advisory agreement created a duty to individual shareholders.In the 191st District Court of Dallas County, the advisors filed a plea to the jurisdiction, a verified plea in abatement, and special exceptions, arguing that the claims were derivative and belonged to the trust, so the shareholders lacked standing and capacity to sue directly. The trial court denied these motions. The advisors sought mandamus relief from the Fifth Court of Appeals, which was denied, and then petitioned the Supreme Court of Texas.The Supreme Court of Texas held that while the shareholders alleged a financial injury sufficient for constitutional standing, they lacked the capacity to sue individually because the advisory agreement did not create a duty to individual shareholders, nor did it confer third-party beneficiary status. The agreement benefited shareholders collectively through the trust, not individually. The court conditionally granted mandamus relief, directing the trial court to vacate its order and dismiss the case with prejudice, holding that shareholders must pursue such claims derivatively and in the proper forum as specified by the trust’s governing documents. View "IN RE UMTH GENERAL SERVICES, L.P." on Justia Law