Justia Texas Supreme Court Opinion Summaries

Plaintiff and the main defendant (Defendant) both wanted an interest in a coalbed methane exploration prospect in Bulgaria. Plaintiff sued Defendant, alleging that Defendant obtained his interest by tortiously interfering with the owner’s contract to convey an interest to Plaintiff. Plaintiff claimed damages for the loss of its interest in the project. A jury found in favor of Plaintiff and awarded $66.5 million in actual damages. The trial court reduced the damages to $31.16 million. The court of appeals reversed in part and rendered judgment on the verdict, awarding Plaintiff the $66.5 million actual damages found by the jury, as well as exemplary damages. On appeal, Defendant argued that the evidence of the fair market value of Plaintiff’s lost interest was too speculative to support the jury’s award of damages. The Supreme Court reversed in part, holding that, under the rule that lost profits cannot be recovered as damages unless proven to a reasonable certainty, Plaintiff was not permitted to recover all of the damages found by the jury. View "Phillips v. Carlton Energy Group, LLC" on Justia Law

In this commercial dispute, Petitioner obtained a $6 million breach-of-contract and tort judgment against Respondents. After filing the lawsuit, Petitioner assigned its claims to its commercial lender. Respondents filed a motion to dismiss for lack of jurisdiction, alleging that Petitioner had no standing to pursue the litigation because it had assigned the claims to the lender. The trial court concluded that Petitioner had standing. The court of appeals vacated the judgment and dismissed for want of jurisdiction. The Supreme Court reversed, holding that the court of appeals failed to consider pertinent evidence before the trial court, and therefore, the cause must be remanded to the trial court for reconsideration. View "Vernco Constr., Inc. v. Nelson" on Justia Law

Plaintiff, a mineral owner, sued Defendant alleging breach of contract, failure to pay royalties, and fraud. The claims centered on three oil and gas leases that Plaintiff, the lessor, executed with Defendant, the lessee. Plaintiff prevailed on the majority of his claims in the trial court. As relevant to this appeal, the jury determined that Plaintiff, in the exercise of reasonable diligence, discovered the fraud less than four years before filing suit. The trial court therefore concluded that the claims were not time barred. The court of appeals reversed, concluding that the fraud should have been discovered, as a matter of law, more than four years before Plaintiff filed suit because Plaintiff should have discovered the relevant information in the Texas Railroad Commission’s public records. The Supreme Court reversed, holding that Plaintiff’s reasonable diligence in discovering the underlying fraud was a question of fact for the jury. Remanded. View "Hooks v. Samson Lone Star, Ltd. P’ship" on Justia Law

In 1998, Glenn Johnson suffered serious work-related injuries. In separate administrative proceedings, the parties contested the details and amounts of the lifetime workers’ compensation benefits Johnson was entitled to. Johnson and his wife filed the instant suit against his employer’s workers’ compensation insurance provider and related individuals and entities (collectively, Crawford), alleging that Crawford engaged in a plan to delay and deny benefits that the Johnsons were entitled to receive. Crawford filed a plea to the jurisdiction and motion for summary judgment, arguing that the Texas Department of Insurance Division of Workers’ Compensation had exclusive jurisdiction over all of the Johnsons’ claims because they arose out of the workers’ compensation claims-handling process. The trial court dismissed the Johnsons’ claims for breach of the common law duty of good faith and fair dealing and for violations of the Texas Insurance Code but refused to dismiss any of the other claims. The Supreme Court conditionally granted mandamus relief, holding that all of the Johnsons’ claims arose out of Crawford’s investigation, handling, and settling of claims for workers’ compensation benefits, and therefore, the Division had exclusive jurisdiction over the Johnsons’ claims. View "In re Crawford & Co." on Justia Law

A property developer filed suit against several defendants involved in a construction project asserting claims for negligence and breach of contract. Defendants filed motions to compel arbitration, which the trial court denied. The court of appeals affirmed. The Supreme Court held that the developer must arbitrate its claims against the general contractor but not its claims against the other defendants, as (1) the developer agreed to arbitrate its claims against the general contractor, and the general contractor did not waive its right to demand arbitration; (2) the developer’s argument that a contractual deadline barred the general contractor’s demand for arbitration was itself a claim that must be arbitrated; (3) the developer did not agree in the general contract to arbitrate its claims against the other defendants; (4) the developer was not equitably estopped from denying its assent to its purported agreement that the other defendants could enforce the general contract’s arbitration provisions; and (5) the subcontracts did not require the parties to arbitrate these claims. View "G.T. Leach Builders, LLC v. Sapphire V.P., L.P." on Justia Law

Gordon Westergren was involved in a lawsuit regarding the purchase of highly desired property. The lawsuit went to mediation, which resulted in National Property Holdings, L.P. (NPH) agreeing to purchase the property. Separately, in exchange for Western’s agreement to settle the lawsuit, Russell Plank, the consultant for NPH, orally promised Westergren that he would receive $1 million plus an interest in the profits from NPH’s future sale of the property. Westergren subsequently signed a release stating that he agreed to relinquish all interest in the property and all claims against NPH and other listed parties in exchange for a total payment of $500,000. Westergren then filed suit, alleging, inter alia, breach of the oral contract and fraud. Defendants asserted that Westergren had released all claims by signing the release and that the oral contract was unenforceable. The jury found in Westergren’s favor on all claims, concluding that Plank fraudulently induced Westergren to sign the release. The Supreme Court held (1) Westergren’s fraudulent inducement failed as a matter of law because he had a reasonable opportunity to read the release before he signed it and elected not to do so; and (2) the oral side agreement did not satisfy the statute of frauds. View "Nat’l Prop. Holdings, L.P. v. Westergren" on Justia Law

Bill Head, who owns and operates the Silver Spur Truck Stop in Pharr, Texas, hired Petroleum Solutions, Inc. to manufacture and install an underground fuel system. After the discovery that a major diesel-fuel release leak had occurred, Head sued Petroleum Solutions for its resulting damages. Petroleum Solutions filed a third-party petition against Titeflex, Inc., the alleged manufacturer of a component part incorporated into the fuel system, claiming indemnity and contribution. Titeflex filed a counterclaim against Petroleum Solutions for statutory indemnity. The trial court rendered judgment in favor of Head and in favor of Titeflex. The court of appeals affirmed. The Supreme Court (1) reversed as to Head’s claims against Petroleum Solutions, holding that the trial court abused its discretion by charging the jury with a spoliation instruction and striking Petroleum Solutions’ defenses, and the abuse of discretion was harmful; and (2) affirmed as to Titeflex’s indemnity claim, holding that Titeflex was entitled to statutory indemnity from Petroleum Solutions and that any error with respect to the indemnity claim was harmless. View "Petroleum Solutions, Inc. v. Head" on Justia Law

When Richmont Holdings, Inc. bought the assets of Superior Recharge Systems, LLC the parties signed an asset Purchase Agreement that contained an arbitration provision. Superior Discharge’s part-owner, Jon Blake, signed an employment contract to continue as general manager of the business. The contract contained a covenant not to compete but not an arbitration provision. After Blake’s employment was terminated, Superior Recharge and Blake (together, Blake) sued Richmont in Denton County for fraud and breach of contract. Richmont then sued Blake individually in Dallas County to enforce the covenant not to compete. The Dallas County suit was subsequently abated. Nineteen months after being sued, Richmont moved to compel arbitration, asserting that Blake’s claims arose out of the Asset Purchase Agreement. The trial court denied the motion, and the court of appeals affirmed. The Supreme Court reversed. On remand, the court of appeals concluded that Richmont had waived arbitration by substantially invoking the judicial process. The Supreme Court reversed, holding that the circumstances of this case did not approach a substantial invocation of the judicial process. Remanded. View "Richmont Holdings, Inc. v. Superior Recharge Sys., LLC" on Justia Law

El Paso Marketing, L.P. provided gas for a power plant owned by Wolf Hollow I, L.P. The gas was transported to the plant through a pipeline owned by Enterprise Texas Pipeline LLC. El Paso sued Wolf Hollow, and Wolf Hollow counterclaimed. El Paso brought a third-party claim against Enterprise, and Wolf Hollow brought a cross-claim against Enterprise. Wolf Hollow’s claims concerned interruptions in gas delivery and allegedly contaminated gas that both required purchases of replacement power. The trial court granted summary judgment for El Paso and Enterprise. The Supreme Court remanded in Wolf Hollow II. On remand, the trial court granted summary judgment for El Paso on Wolf Hollow’s gas-quality claim and issued declarations regarding the claim. The court of appeals in Wolf Hollow III concluded that the Supreme Court had rejected the declarations in Wolf Hollow II and thus remanded the case for trial on Wolf Hollow’s claims for replacement-power damages for the failure to deliver quality gas. The Supreme Court reversed the court of appeals’ judgment relating to Wolf Hollow’s gas-quality claim for replacement-power damages, holding that the court of appeals erred in Wolf Hollow III insofar as it held that the Court’s Wolf Hollow II decision precluded it from reviewing questions regarding whether the declarations applied to that claim, and otherwise affirmed. View "El Paso Marketing, L.P. v. Wolf Hollow I, L.P." on Justia Law

Petitioner had a one-year contract to serve as the head women’s basketball coach and a professor with Trinity Valley Community College (TVCC), a local governmental entity. Five months into the contract, TVCC fired Petitioner. Petitioner sued for breach of contract. The trial court dismissed the case, concluding that TVCC was immune from suit. The court of appeals affirmed, concluding that the Local Government Contract Claims Act, which waives a local governmental entity’s immunity from suit for breach of a services contract, does not waive immunity from suit for breach of employment contracts. The court of appeals affirmed. The Supreme Court reversed, holding that the Act covers government employment contracts generally, and therefore, TVCC’s immunity from suit had been waived for Petitioner’s breach-of-contract claim. View "Damuth v. Trinity Valley Cmty. College" on Justia Law