Justia Texas Supreme Court Opinion Summaries

The Supreme Court reversed the decision of the court of appeals determining that Musa “Moses” Musallam failed to preserve error to challenge the jury’s finding that he agreed to sell his business to Amar Ali, holding that Musallam was not precluded from challenging the jury's finding.Musallam and Ali entered into a written agreement relating to the sale of Musallam’s business to Ali. Musallam refused to close and, instead, sought a declaratory judgment that the agreement was unenforceable. During trial, Musallam requested a jury question asking whether he and Ali had agreed to the sale of the business and did not object to the trial court’s including the question in the jury charge. The trial court rendered judgment for Ali based on the jury’s findings. On appeal, Musallam challenged the jury’s finding that he agreed to sell the business to Ali. The court of appeals determined that because Musallam did not object to the jury question at issue, he failed to preserve error to challenge either its inclusion in the charge or the jury’s answer to it. The Supreme Court disagreed, holding that Musallam’s requesting the jury question did not preclude him from later challenging the jury’s answer to the question. View "Musallam v. Ali" on Justia Law

Having granted Petitioner’s motion for rehearing, the Supreme Court withdrew the judgment and opinion issued on June 1, 2018, holding that the contract in this case arose from a municipality’s performance of a propriety function, so governmental immunity did not apply.After the City of Jacksonville terminated James and Stacy Wasson’s (together, Wasson) leases, Wasson filed this suit alleging that the City breached the lease agreements and seeking declaratory and injunctive relief. The City moved for summary judgment on the grounds that governmental immunity barred Wasson’s claims. The trial court granted the motion. The court of appeals affirmed based on governmental immunity, rejecting Wasson’s argument that the governmental/proprietary dichotomy applies to breach of contract claims. The Supreme Court reversed and remanded, ruling that the dichotomy applies whether a municipality commits a tort or breaches a contract. On rehearing, the Court held (1) the nature of the function the City was performing when it entered into the contract governed the analysis as to whether governmental immunity barred the breach of contract claim; and (2) the City was engaged in a propriety function when it allegedly breached the lease agreements, and therefore, governmental immunity did not bar Wasson’s claims. View "Wasson Interests, Ltd. v. City of Jacksonville, Texas" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the trial court’s denial of settlement credits in this case, holding that the trial court erred in failing to apply the one-satisfaction rule and therefore erred in denying the nonsettling defendant the settlement credits they sought.Plaintiff sued Defendants alleging, inter alia, breach of loan note and guaranty agreements, fraud, and conspiracy. The jury awarded Plaintiff damages of $2,665,832 and attorney’s fees. In response to Plaintiff’s motion for judgment, Defendants asserted that under the one-satisfaction rule, they were entitled to offset the final judgment by the amounts the four settling defendants paid to Plaintiff. However, the trial court rendered judgment against Defendants for the full jury award. The Supreme Court reversed, holding that Defendants were entitled to reduce the judgment by the total amount of the four settlements Plaintiff received and any applicable interest. View "Sky View at Las Palmas, LLC v. Mendez" on Justia Law

The Supreme Court held that trial courts must expressly rule on objections in writing for error to be preserved.Plaintiffs sued Allstate Texas Lloyds and one of its adjusters (collectively, Allstate) asserting contractual and extra-contractual claims. Allstate moved for summary judgment. Plaintiffs filed a summary-judgment response that referred to certain pieces of summary-judgment evidence, including an affidavit, but Plaintiffs failed to attach any evidence to their response. The only evidence Plaintiffs provided was filed late. Allstate objected in writing to Plaintiffs’ summary-judgment evidence on multiple grounds. The trial court granted summary judgment for Allstate but did not specify the grounds for its judgment. The court of appeals affirmed, holding that Plaintiffs’ only summary-judgment evidence was incompetent. The Supreme Court reversed, holding (1) unless Allstate complained of a defect in the evidence’s substance, rather than its form, it was obligated not only to object but also to obtain a ruling on its objection; and (2) Allstate’s objections were waived in this case. View "Seim v. Allstate Texas Lloyds" on Justia Law

In this divorce case, the Supreme Court affirmed the judgment of the court of appeals affirming the finding of the trial court that Wife’s attempt to rescind a premarital agreement triggered a clause in the agreement under which Wife lost a $5 million payment otherwise due to her.Prior to the parties’ marriage, they entered into an “Agreement in Contemplation of Marriage” under which Husband would make a lump-sum cash payment to Wife upon the entry of a divorce decree. The Agreement also contained a “no-contest” or “forfeiture” clause, under which Wife would lose her contractual right to the lump-sum payment. After Husband filed for divorce, Wife requested rescission of the Agreement. Ultimately, the trial court concluded that Wife forfeited any cash payment under the Agreement. The court of appeals affirmed. The Supreme Court affirmed, holding that by unsuccessfully seeking rescission of the Agreement and pursuing that remedy throughout the litigation, Wife lost her contractual right to the lump-sum payment under the Agreement. View "In re Marriage of I.C." on Justia Law

The common law rule against perpetuities does not invalidate a grantee’s future interest in the grantor’s reserved non-participating royalty interest (NPRI).Lorene Koopmann and her two children sought declaratory judgment against Burlington Resources Oil & Gas Company, L.P. and Lois Strieber to construe a warranty deed by which Strieber conveyed fee simple title to a tract of land to Lorene and her late husband. Under the deed, Strieber reserved a fifteen-year, one-half NPRI. The Koopmans claimed that they were the sole owners of an NPRI as of December 27, 2011. They also asserted claims against Burlington, which leased the tract from the Koopmanns, for breach of contract and other claims. The trial court granted summary judgment for the Koopmans as to the declaratory action and granted summary judgment for Burlington on the negligence and negligence per se claims. The court of appeals affirmed in part and reversed in part. The Supreme Court held (1) the rule against perpetuities does not invalidate the Koopmann’s future interest in the NPRI; (2) Tex. Nat. Res. Code 91.402 does not preclude a lessor’s common law claim for breach of contract; and (3) the court of appeals properly entered judgment as to attorney’s fees pursuant to Tex. R. Civ. P. 91a. View "ConocoPhillips Co. v. Koopmann" on Justia Law

The Supreme Court reversed the decision of the court of appeals holding that a cause of action for acknowledgment of a debt must be “specifically and clearly” pleaded “in plain and emphatic terms” because this holding conflicts with Tex. R. Civ. P. 47(a), which provides that a pleading is “sufficient” if it gives “fair noice of the claim involved.”A Trust sued Defendants seeking payment on a debt. Defendants moved for summary judgment arguing that the Trust’s claims were barred by the statute of limitations because the Trust had not properly pleaded acknowledgment. The trial court agreed and granted summary judgment for Defendants. The court of appeals affirmed, concluding that while the Trust had raised acknowledgment in response to Defendants’ motion for summary judgment, it had failed to plead acknowledgement as a cause of action because it had not done so “specifically and clearly” and in “plain and emphatic terms.” The Supreme Court reversed and remanded, holding that the Trust provided fair notice to Defendants of its claim on their acknowledgment and thus satisfied Rule 47, and the court of appeals erred in requiring a higher standard. View "DeRoeck v. DHM Ventures, LLC" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the court of appeals in this defamation, breach of contract, and fraudulent inducement case.After Defendant, Plaintiff’s employer, offered him an oral deal to “buy in” the business in exchange for managing two automobile dealerships, Plaintiff was falsely accused of taking illegal kickbacks on used-car acquisitions and lost his job. The jury found that Defendant defrauded and defamed Plaintiff but did not find that the parties agreed to a buy-in deal that included interests in the dealerships and their underlying real estate. The jury awarded Plaintiff $2.2 million in defamation damages and $383,150 in fraud damages. The trial court rendered judgment on the jury’s verdict. The court of appeals reversed and rendered a take-nothing judgment. The Supreme Court held (1) the jury’s failure to find that the parties agreed to the specific contract terms submitted in the contract question did not preclude Plaintiff from recovering the value of the disputed dealership interests as benefit-of-the-bargain damages under a fraud theory that required proof of an enforceable contract; and (2) legally sufficient evidence supported the damages awarded for loss of reputation and mental anguish in the past, but no evidence supported the existence of future damages or a finding that the kickback allegations caused any lost-income damages. View "Anderson v. Durant" on Justia Law

In this insurance dispute, the Supreme Court held that the issue of whether the trial court properly disregarded some of the jury’s findings should be remanded to the court of appeals for reconsideration in light of this Court’s decision in USAA Texas Lloyds Co. v. Menchaca, __ S.W.3d __ (Tex. 2018).Plaintiffs sued their insurer, State Farm, for breach of contract and Insurance Code violations. The jury found that both parties breached the insurance contract but that Plaintiffs breached first. The jury then awarded damages for State Farm’s breach of the policy and for Plaintiffs’ extra-contractual claims. The trial court disregarded two of the jury’s findings about Plaintiffs’ breach of the insurance contract and rendered judgment for Plaintiffs. The court of appeals affirmed. While State Farm's appeal was pending, the Supreme Court issued its final opinion and judgment in Menchaca, which clarified whether an insured can recover policy benefits based on an insurer’s violation of the Texas Insurance Code even though the jury failed to find that the insurer failed to comply with its obligations under the policy. On appeal, the Supreme Court held (1) State Farm’s first issue should be remanded for reconsideration in light of Menchaca; and (2) as to the remaining issues, the court of appeals’ judgment is affirmed. View "State Farm Lloyds v. Fuentes" on Justia Law

The nature of the function a municipality was performing when it entered into a contract governs the analysis of whether the municipality was engaged in its governmental or proprietary function and thus whether the municipality was immune from suit.Plaintiff filed this suit alleging that the City of Jacksonville breached its lease agreements with Plaintiff. The City filed a motion for summary judgment arguing that governmental immunity barred the breach of contract claim. The trial court granted the motion. The court of appeals affirmed based on governmental immunity, concluding that the governmental/proprietary dichotomy that applies to tort claims does not apply to breach of contract claims. The Supreme Court reversed, holding that the dichotomy applies whether a municipality commits a tort or breaches a contract. On remand, the court of appeals held that governmental immunity applied to bar Plaintiff’s contract claim because the claim arose from the City’s performance of a governmental function. The Supreme Court reversed, holding that the contract claim arose from the City’s performance of a proprietary function so governmental immunity did not apply. View "Wasson Interests, Ltd. v. City of Jacksonville" on Justia Law