Justia Texas Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals in this case involving the construction of an “opaquely worded oil and gas agreement,” holding that Burlington Resources may deduct post-production costs when calculating royalty payments due to Amber Harvest on its oil and gas leases.Amber Harvest, an affiliate of Texas Crude Energy, owned overriding royalty interests in the oil and gas leases operated by Burlington. Texas Crude sued Burlington, alleging that the parties’ agreements prohibited Burlington from charging post-production costs to the royalty holder. All parties agreed that the contracts at issue were unambiguous. After construing the agreements based on the language the parties chose the Supreme Court held that Burlington’s construction of the parties’ contracts was correct and that Burlington may deduct post-production costs when calculating royalty payments. View "Burlington Resources Oil & Gas Co. v. Texas Crude Energy, LLC" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming an award of actual and punitive damages in favor of Carduco, Inc., a Mercedes-Benz franchisee, on its fraud claim against Mercedes-Benz USA, LLC, holding that the court of appeals erred in affirming the trial court’s judgment, as modified.In its complaint Caduco alleged that Mercedes fraudulently induced it to purchase the assets of the previous Mercedes-Benz dealer in Harlingen, Texas. Specifically, Carduco argued that Mercedes had promised Carduco that, if it agreed to take on the franchise in Harlington, Carduco would eventually be able to relocate to the McAllen area as the exclusive Mercedes-Benz dealership there. A jury found for Carduco and awarded both actual and punitive damages. The court of appeals affirmed as modified by a suggestion of remittitur of the punitive damages award. The Supreme Court reversed, holding that the parties’ written agreement directly contradicted Carduco’s purported belief that Mercedes had promised to McAllen area to it, thereby negating Carduco’s justifiable reliance as a matter of law. The Court then rendered judgment that Carduco take nothing. View "Mercedes-Benz USA, LLC v. Carduco, Inc." on Justia Law

In this dispute by a third party claiming the benefit of a blanket subrogation waiver by virtue of a written contract with the insured, the Supreme Court reversed the conclusion of the court of appeals that the subrogation waiver was inoperative as to an injured worker’s recovery against the third party, holding that the endorsement waiving the carrier’s recovery rights was effective as to the bodily injury claim.In the contract at issue, the insured agreed to procure a waiver of “all rights of subrogation and/or contribution against [the third party]…to the extent liabilities are assumed by [the insured].” The court of appeals read the “to the extent liabilities are assumed” limitation into the endorsement and ruled that the subrogation waiver did not apply to the injured worker’s recovery against the third party because the insured was not contractually obligated to indemnify the third party for the loss. The Supreme Court reversed, holding that the endorsement referred to another contract only to identify who may claim the waiver and at what operations but did not refer to, and thus did not incorporate, any other contract limitations. View "Exxon Mobil Corp. v. Insurance Co. of State of Pennsylvania" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the trial court that Plaintiff’s implied warranty claim was actionable only under the Deceptive Trade Practices-Consumer Protection Act (DTPA), Tex. Bus. & Com. Code 17.41-17.63, holding that the claim for breach of implied warranty of good and workmanlike repairs in this case was not brought under the DTPA and thus was not covered by the DTPA’s two-year limitations period.Plaintiff sought damages for injuries to himself and his small plane when the plane’s engine failed and it crash-landed. Defendant moved to strike Plaintiff’s petition, arguing that the DTPA’s two-year statute of limitations applied. The trial court agreed with Defendant and struck the petition. The court of appeals affirmed. The Supreme Court reversed, holding that Plaintiff’s breach of implied warranty claim was not barred by the DTPA limitations period. View "Nghiem v. Sajib" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the court of appeals that the evidence was legally sufficient to support the trial court’s award of both actual and punitive damages as to all Plaintiffs in this lawsuit, holding that Plaintiffs were entitled to actual damages but were not entitled to punitive damages.Plaintiffs brought suit against Bombardier Aerospace Corporation for breach of contract, breach of express warranty, and fraud. The jury found in favor of Plaintiffs, and the trial court awarded both actual and punitive damages. The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) the evidence was legally sufficient to support the award of actual damages to Plaintiffs; but (2) the limitation-of-liability clauses in the parties’ agreements barred the punitive damages award under the circumstances. View "Bombardier Aerospace Corp. v. SPEP Aircraft Holdings LLC" on Justia Law

The Supreme Court affirmed the trial court’s denial of Sabre Travel International, Ltd.’s motion to dismiss Deutsche Lufthansa Airline Group’s tortious interference with contract claim based on preemption, holding that the federal Airline Deregulation Act (ADA) did not preempt an airline’s claim for tortious interference with contract brought under state law.The trial court denied Sabre’s motion to dismiss but certified a legal question under Tex. Civ. Prac. & Rem. Code 51.014(d) providing for permissive interlocutory appeals. The court of appeals denied the permissive interlocutory appeal without explanation. After Sabre filed a petition for review in the Supreme Court, Lufthansa argued that the Court had no jurisdiction to hear the case because the court of appeals denied the permissive appeal. The Supreme Court held (1) under Tex. Gov. Code 22.225(d), an appellate court’s denial of a permissive interlocutory appeal does not prevent the Supreme Court from reviewing the merits of the interlocutory order; and (2) there was no preemption under the ADA. View "Sabre Travel International, Ltd. v. Deutsche Lufthansa AG" on Justia Law

The Supreme Court reversed the judgment of the court of appeals holding that Emergency Medical Training Services (EMTS) did not provide clear and specific evidence under the Texas Citizens Participation Act (TCPA), Tex. Civ. Prac. & Rem. Code 27.003, of a prima facie case that a former employee (Defendant) breached nondisclosure agreements she signed in connection with her employment, holding that EMTS established a prima facie case of each essential element of a breach of contract cause of action.EMTS sued Defendant for breach of contract and moved for injunctive relief. Defendant filed a motion to dismiss pursuant to the TCPA, arguing that her actions were an exercise of her right to petition and her right of free speech. The trial court denied the motion to dismiss. The court of appeals reversed, concluding that EMTS established all the elements of a breach of contract claim with the exception of the damages element. The Supreme Court reversed, holding that EMTS established a prima facie case by clear and specific evidence of each essential element of a breach of contract cause of action. View "S&S Emergency Training Solutions, Inc. v. Elliott" on Justia Law

In this contract dispute over an offset provision in an oil and gas lease the Supreme Court reversed the judgment of the court of appeals reversing the trial court’s judgment in the lessee’s favor, holding that the court of appeals read a requirement into the lease that its unambiguous language did not support.In reversing, the court of appeals concluded that the lessee did not conclusively prove that it complied with the offset provision. The Supreme Court reversed the court of appeals’ judgment and reinstated the trial court’s judgment s modified to remove the award of appellate attorney’s fees, holding (1) the offset provision contained specific requirements, and the lessee met those requirements; and (2) the court of appeals’ reading of the offset provision to contain a proximity requirement constituted a significant deviation from the language the parties chose. View "Murphy Exploration & Production Co. v. Adams" on Justia Law

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