Justia Texas Supreme Court Opinion Summaries

The common law rule against perpetuities does not invalidate a grantee’s future interest in the grantor’s reserved non-participating royalty interest (NPRI). In addition, section 91.402 of the Texas Natural Resources Code does not preclude a lessor’s common law claim for breach of contract.The court of appeals concluded that the rule did not bar the grantees’ future interest in the NPRI. The court, however, found that the reservation’s savings clause was ambiguous and remanded the case for a jury to determine the proper interpretation. The court held that section 91.402 does not bar a claim for breach of contract. Finally, while determining that several of the grantees’ claims failed as a matter of law, the court of appeals upheld the trial court’s award of attorney’s fees against the grantor pursuant to Tex. R. Civ. P. 91a. The Supreme Court affirmed. View "ConocoPhillips Co. v. Koopmann" on Justia Law

In construing a settlement agreement that conditioned resumption of uranium mining operations on restoration of well-water quality if pre-mining data showed the water had been suitable for specified uses before prior mining operations began, the lower courts impermissibly employed surrounding facts and circumstances to determine subjective intent and interpolate constraints not found in the contract’s unambiguous language.Specifically, the lower courts held that, in determining whether a restoration obligation existed as to a disputed well, the mining company was contractually required to ignore data showing no pre-mining suitability. The Supreme court reversed and rendered judgment for the mining company, holding that the court of appeals clearly erred by relying on extrinsic evidence of intent to add to, alter, and augment the settlement agreements plain and unambiguous language. View "URI, Inc. v. Kleberg County" on Justia Law

The lessee of certain mineral interests could not justifiably rely on extra-contractual representations by the lessor’s agent despite “red flags” and a negation-of-warranty clause in the sales documents explicitly placing the risk of title failure on the lessee.In its complaint, the lessee alleged breach of contract, fraud, and negligent misrepresentation. Following a pre-trial conference, the trial court issued an order under Tex. R. Civ. P. 166(g) disposing of all of the lessee’s claims, concluding (1) the unambiguous terms of the letter of intent and leases precluded the lessee’s contract claim; and (2) as a matter of law, the lessee could not establish the justifiable-reliance element of its fraud and negligent-misrepresentation claims. The court of appeals affirmed the trial court's ruling regarding the contract claim but reversed on fraud and negligent misrepresentation. The Supreme Court reversed the court of appeals and reinstated the trial court’s judgment, holding (1) justifiable reliance was an essential element of the lessee’s remaining causes of action; and (2) as a matter of law, the lessee could not show justifiable reliance. View "JPMorgan Chase Bank, N.A. v. Orca Assets G.P., LLC" on Justia Law

A defendant can prevail on the merits of its counterclaims against a governmental entity when the governmental entity recovers monetary relief on its affirmative claims by filing a lien and a lis pendens and then nonsuits its affirmative claims where the defendant seeks an offset against the amount the governmental entity recovered through the litigation process.Petitioner, which operated pecan orchards, entered into water-supply agreements with Respondent, a political subdivision. Respondent sued Petitioner for breach of contract. Petitioner counterclaimed for breach of contract and fraud. After Respondent recorded a crop lien and a lis pendens against Petitioner’s orchards, Petitioner paid Respondent the amount it sought to remove the lien and lis pendens but continued to pursue its counterclaims seeking an offset against that payment. Respondent later nonsuited its claims. The trial court granted summary judgment for Respondent, ordering that Petitioner take nothing on its counterclaims. The court of appeals affirmed. The Supreme Court reversed, holding that the court of appeals erred in concluding that Petitioner could not prevail on the merits of its counterclaims merely because Respondent obtained its recovery by filing a lien and lis pendens. View "C. Borunda Holdings, Inc. v. Lake Proctor Irrigation Authority of Comanche County" on Justia Law

A defendant can prevail on the merits of its counterclaims against a governmental entity when the governmental entity recovers monetary relief on its affirmative claims by filing a lien and a lis pendens and then nonsuits its affirmative claims where the defendant seeks an offset against the amount the governmental entity recovered through the litigation process.Petitioner, which operated pecan orchards, entered into water-supply agreements with Respondent, a political subdivision. Respondent sued Petitioner for breach of contract. Petitioner counterclaimed for breach of contract and fraud. After Respondent recorded a crop lien and a lis pendens against Petitioner’s orchards, Petitioner paid Respondent the amount it sought to remove the lien and lis pendens but continued to pursue its counterclaims seeking an offset against that payment. Respondent later nonsuited its claims. The trial court granted summary judgment for Respondent, ordering that Petitioner take nothing on its counterclaims. The court of appeals affirmed. The Supreme Court reversed, holding that the court of appeals erred in concluding that Petitioner could not prevail on the merits of its counterclaims merely because Respondent obtained its recovery by filing a lien and lis pendens. View "C. Borunda Holdings, Inc. v. Lake Proctor Irrigation Authority of Comanche County" on Justia Law

Defendants’ failure to fully comply with a temporary restraining order did not justify sanctions even more severe than death-penalty sanctions imposed by the trial court.Plaintiffs sought a temporary restraining order (TRO) against Defendants. Without taking evidence, the court signed a TRO prohibiting Defendants from engaging in certain conduct. Plaintiffs later filed a motion for contempt and sanctions, alleging that Defendants knowingly violated the TRO. The trial court granted the motion in an order stating that “death penalty sanctions should be imposed” against Defendants. The court then awarded sanctions of $897,938. The court of appeals affirmed. The Supreme Court reversed and remanded the case, holding (1) Defendants knowingly violated the TRO without a compelling excuse; but (2) the extreme sanction imposed for the violations of the TRO was an abuse of discretion. View "Altesse Healthcare Solutions, Inc. v. Wilson" on Justia Law

In this case involving an arbitration provision in short-term loan contracts the Supreme Court affirmed the judgment of the court of appeals ruling (1) the borrowers’ claims against the lender came within the arbitration provision, and (2) the lender did not waive its right to arbitrate by providing information to the district attorney that checks written to the lender by the borrowers had been returned for insufficient funds.The borrowers sued the lender, claiming that the lender wrongfully used the criminal justice system to collect unpaid loans by filing false charges against them. The lender responded by filing a motion to compel arbitration. The trial court denied the motion, concluding that the arbitration clause was inapplicable because the borrowers' claims related solely to the lender’s illegal use of the criminal justice system and that the lender waived its right to arbitration by substantially invoking the judicial process. The court of appeals reversed. The Supreme Court affirmed, holding (1) the borrowers’ claims were within the scope of the arbitration provision; and (2) the lender did not substantially invoke the judicial process, and therefore, there was no evidence to support the trial court’s finding the the lender waived its right to arbitrate. View "Henry v. Cash Biz, LP" on Justia Law

In this case involving an arbitration provision in short-term loan contracts the Supreme Court affirmed the judgment of the court of appeals ruling (1) the borrowers’ claims against the lender came within the arbitration provision, and (2) the lender did not waive its right to arbitrate by providing information to the district attorney that checks written to the lender by the borrowers had been returned for insufficient funds.The borrowers sued the lender, claiming that the lender wrongfully used the criminal justice system to collect unpaid loans by filing false charges against them. The lender responded by filing a motion to compel arbitration. The trial court denied the motion, concluding that the arbitration clause was inapplicable because the borrowers' claims related solely to the lender’s illegal use of the criminal justice system and that the lender waived its right to arbitration by substantially invoking the judicial process. The court of appeals reversed. The Supreme Court affirmed, holding (1) the borrowers’ claims were within the scope of the arbitration provision; and (2) the lender did not substantially invoke the judicial process, and therefore, there was no evidence to support the trial court’s finding the the lender waived its right to arbitrate. View "Henry v. Cash Biz, LP" on Justia Law

If a plaintiff sues both public employees and their employer, section 101.106(e) of the Texas Tort Claims Act requires that the employees be immediately dismissed upon the employer’s motion, and this statutory right to dismissal accrues when the motion is filed and is not impaired by later amendments to the pleadings or motion. Respondent sued a government unit and some of its employees. The Attorney General moved to dismiss all but the tort claims against the employer, arguing that Respondent's contract claim against the employer, a state agency, was barred by sovereign immunity and that the tort claims against the employees were required to be dismissed under section 101.106(e). Thereafter, Respondent amended his petition to drop his tort claims against the employer, leaving the employees as the only tort defendants. The amended petition’s only claim against the employer was for breach of contract. The trial court dismissed Respondent's contract claim against the employer but denied dismissal of his tort claims against the employees. On appeal, the Supreme Court rendered judgment dismissing Respondent's state-law tort claims against the employees, holding that, following Respondent's amended petition, Defendants remained entitled to dismissal of the tort claims asserted against the employees in Respondent's original petition, as requested in Defendants’ original motion to dismiss. View "University of Texas Health Science Center at Houston v. Rios" on Justia Law

In this dispute involving mineral interests pooled for natural gas production, lessors and other stakeholders alleged that the lessee underpaid royalties owed to them under their mineral leases and pooling agreements. The issues presented in this appeal centered on the lessee’s efforts to avoid a contractual obligation to pay royalties to the overlapping unit stakeholders for production from a zone shared by the two pooled units. The lower courts held that the agreement to pay royalties was enforceable. The Supreme Court affirmed, holding (1) ineffective conveyance of title does not preclude the lessee’s liability under a contract theory; (2) the lessee’s quasi-estoppel and scrivener’s error defenses to contract enforcement failed as a matter of law; and (3) the lessee was not entitled to recoup royalty payments from stakeholders in another pooled unit; (4) this court’s decision in Hooks v. Samson Lone Star, Ltd. Partnership, 457 S.W. 3d 52 (Tex. 2015) precluded the unpooling stakeholders’ claims; and (5) the court of appeals properly construed a proportionate-reduction clause to award royalties owed to the overlapping unit stakeholders in accordance with their fifty percent mineral-interest ownership. View "Samson Exploration, LLC v. T.S. Reed Properties, Inc." on Justia Law