Justia Texas Supreme Court Opinion Summaries

Ray Fischer transferred his business assets to CTMI, LLC pursuant to a written asset-purchase agreement. CTMI later filed a second amended petition alleging that portions of the asset-purchase agreement were unenforceable “agreements to agree.” The trial court entered judgment in favor of Fischer. The court of appeals reversed and rendered judgment that the disputed portion of CTMI’s payment obligations was an unenforceable agreement to agree. The Supreme Court reversed, holding that the payment provision at issue was enforceable because its material terms were sufficiently definite to enable a court to determine CTMI’s obligation and provide a remedy for its breach. View "Fischer v. CTMI, LLC" on Justia Law

Plaintiff sued Defendant for breach of contract and for wrongfully discharging him in retaliation for filing a workers’ compensation claim in good faith. Plaintiff’s breach of contract claim related to Defendant’s failure to remit accrued vacation pay upon his termination. A jury found in Plaintiff’s favor. The trial court rendered judgment in favor of Plaintiff, awarding him past and future lost earnings, employee benefits, and other damages. Defendant appealed the portion of the judgment on the retaliation claim. The court of appeals affirmed. The Supreme Court reversed and rendered a take-nothing judgment in favor of Defendant on Plaintiff’s retaliation claim, holding that no evidence supported the jury’s verdict on that claim. View "Kingsaire, Inc. v. Melendez" on Justia Law

Plaintiffs filed suit against Defendant, alleging breach of contract and misappropriation of trade secrets. Concerned by Plaintiffs’ counsel’s (Counsel) exposure to certain documents as a result of Counsel working “closely” with Defendant’s former finance manager, Defendant moved to disqualify Counsel from representing Plaintiff. The special master denied the motion to disqualify. The trial court, however, ordered Counsel’s disqualification. The court of appeals subsequently denied Plaintiffs’ petition for mandamus relief. The Supreme Court conditionally granted mandamus relief, holding that the trial court improperly disqualified Counsel under In re American Home Products Corp., as the American Home Products screening requirement does not govern a fact witness with information about his former employer if his position with that employer existed independently of litigation and he did not primarily report to lawyers. Rather, to the extent that a fact witness discloses his past employer’s privileged and confidential information, the factors outlined in In re Meador should guide the trial court’s decision regarding disqualification. View "In re RSR Corp. and Quemetco Metals Ltd., Inc." on Justia Law

Kachina Pipeline Co., a pipeline operator, and Michael Lillis, a natural-gas producer, entered into a Gas Purchase Agreement. Kachina bought, transported, and resold Lillis’s gas according to the Agreement. Lillis later entered into a separate purchase agreement and constructed his own pipeline to one of Davis Gas Processing’s plants. Thereafter, Lillis sued Kachina, asserting that Kachina breached the Agreement by deducting the costs of compression that occurred after he delivered the gas to Kachina. Lillis also brought a fraud claim, asserting that Kachina represented it would release him from the Agreement. Kachina counterclaimed for breach of the Agreement and seeking declarations that it had the right to deduct compression charges under the Agreement. The trial court granted summary judgment for Kachina, declaring that the Agreement entitled Kachina to deduct the costs of compression from its payments to Lillis and that the Agreement gave Kachina the option to extend the arrangement for an additional five-year term. The court of appeals reversed, concluding that the agreement unambiguously allowed neither the disputed deductions nor a five-year extension. The Supreme Court affirmed, holding that the Agreement did not allow Kachine to deduct compression costs or support a five-year extension. View "Kachina Pipeline Co., Inc. v. Lillis" on Justia Law

In 2011, Respondents sued Petitioner over two acres of land that Petitioner purchased from Respondents in 2006 through a trust. The deed mistakenly - but unambiguously - failed to reserve mineral rights. When Respondents discovered the error, they demanded that Petitioner issue a correction deed, but Petitioner claimed that the statute of limitations barred Respondents’ claims over the deed. Respondents urged the trial court to declare as a matter of law that the deed did not convey mineral rights and argued that Petitioner breached the sales contract by refusing to execute a correction deed. The trial court ruled that Respondents’ claims were time-barred. The court of appeals reversed, concluding that the discovery rule delayed the accrual of limitations for a deed-reformation claim. The Supreme Court reversed, holding (1) a plainly obvious and material omission in an unambiguous deed is not a type of injury for which the discovery rule is available because it charges parties with irrefutable notice for limitations purposes; (2) Tex. Prop. Code Ann. 13.002 provides all persons, including the grantor, with notice of the deed’s contents as well; and (3) therefore, a grantor who signs an unambiguous deed is presumed as a matter of law to have immediate knowledge of material omissions. Accordingly, Respondents’ suit was untimely. View "Cosgrove v. Cade" on Justia Law

At issue in this case was the scope of attorneys’ immunity from civil liability to non-clients. Philip Byrd and Nancy Simenstad commenced divorce proceedings. Simenstad was represented in the proceedings by Cantey Hanger, LLP. The parties eventually settled. The decree awarded Simenstad three aircraft as her separate property, including a Piper Seminole that had been owned by Lucy Leasing, Co., LLC. Byrd and two of the companies awarded to Byrd in the decree later sued Simenstad and Cantey Hanger alleging that after the decree was entered, Defendants falsified a bill of sale transferring the Piper Seminole from Lucy Leasing to a third party in order to shift tax liability for the aircraft to Byrd in contravention of the divorce decree. The trial court granted summary judgment to Cantey Hanger on attorney-immunity grounds. The court of appeals reversed, concluding that the firm’s alleged misconduct was unrelated to the divorce litigation and that the firm had not conclusively established its entitlement to immunity. The Supreme Court reversed the court of appeals and reinstated the trial court’s judgment, holding that Canter Hanger conclusively established that it is immune from civil liability to Plaintiffs, and therefore, the trial court’s grant of summary judgment was proper. View "Cantey Hanger, LLP v. Byrd" on Justia Law

At issue in this residential construction dispute was whether the statutory cap on exemplary damages is waived if not pleaded as an affirmative defense or avoidance. The trial court affirmed an exemplary damages award in excess of the statutory cap because Petitioner did not assert the cap until her motion for a new trial. The court of appeals affirmed the exemplary damages award, concluding that the statutory cap on exemplary damages did not apply because Petitioner failed to expressly plead the cap as an affirmative defense. The Supreme Court (1) reversed the court of appeals’ judgment in relation to the exemplary cap, holding (i) the exemplary damages cap is not a matter ”constituting an avoidance or affirmative defense” and need not be affirmatively pleaded because it applies automatically when invoked and does not require proof of additional facts, and (ii) because Petitioner timely asserted the cap in her motion for new trial, the exemplary damages must be capped at $200,000; and (2) affirmed in all other respects. View "Zorilla v. Aypco Constr. II, LLC" on Justia Law

In a 1996 purchase and sale agreement Torch Energy Advisors Inc. sold its leasehold interests in undeveloped oil and gas fields located under federal waters. Certain interests were excluded from the conveyance. A decade later, a federal court determined that the federal government had repudiated the mineral leases because a statute enacted before the conveyance had been applied in a manner that precluded development of the leasehold interests. Consequently, the purchaser’s successor in interest, Plains Exploration & Production Company, was awarded restitution of the lease-bonus payments that Torch’s predecessor had paid to secure the leases. Torch claimed an ownership interest in approximately half of the judgment based on the terms of the excluded-assets provision in the 1996 agreement. Plains declined to pay. Torch sued, alleging contract and equitable theories of recovery. The trial court entered a take-nothing judgment in Plains’s favor. The court of appeals reversed in part and remanded the equity claim for a trial on the merits, concluding that Torch’s equitable claim hinged on the proper construction of the 1996 agreement’s terms. The Supreme Court reversed, holding that the relevant excluded-assets provisions in the 1996 agreement were unambiguous and, as a matter of law, Torch did not retain ownership of the claimed asset. View "Plains Exploration & Prod. Co. v. Torch Energy Advisors, Inc." on Justia Law

Kachina Pipeline Co., a pipeline operator, and Michael Lillis, a natural-gas producer, entered into a Gas Purchase Agreement. Kachina bought, transported, and resold Lillis’s gas according to the Agreement. Lillis later entered into a separate purchase agreement and constructed his own pipeline to one of Davis Gas Processing’s plants. Thereafter, Lillis sued Kachina, asserting that Kachina breached the Agreement by deducting the costs of compression that occurred after Lillis delivered the gas to Kachina. Lillis also brought a fraud claim, asserting that Kachina represented it would release him from the Agreement. Kachina counterclaimed for breach of the Agreement and seeking declarations that it had the right to deduct compression charges under the Agreement. The trial court granted summary judgment for Kachina, declaring that the Agreement entitled Kachina to deduct the costs of compression from its payments to Lillis and that the Agreement gave Kachina the option to extend the arrangement for an additional five-year term. The court of appeals reversed. The Supreme Court affirmed, holding that the Agreement unambiguously allowed neither the disputed deductions nor a five-year extension. Remanded. View "Kachina Pipeline Co., Inc. v. Lillis" on Justia Law

This case arose out of a warehouse fire in Pasadena, Texas. Plaintiffs, the company that leased the warehouse and the company that stored materials in the warehouse, sued Defendants, the suppliers of the chlorpyrifos that the lessee used in the warehouse, for manufacturing and marketing defect, breach of contract, negligence, and other causes of action. The jury found that the chlorpyrifos was defective and that Defendants breached the parties’ contract. After the trial court entered judgment for Plaintiffs, Defendants moved for judgment notwithstanding the verdict. The trial court granted the motion, concluding that the testimony of all four of Plaintiffs’ experts was unreliable and constituted no evidence of negligence, manufacturing defect, and causation. The court of appeals reversed, concluding that each expert’s individual testimony was reliable, and therefore, the experts’ collective testimony was reliable. The Supreme Court reversed, holding (1) the testimony of all four experts was unreliable; and (2) consequently, there was no evidence of an essential element of Plaintiffs’ claims. View "Gharda USA, Inc. v. Control Solutions, Inc." on Justia Law