Justia Texas Supreme Court Opinion Summaries

Plaintiffs, two groups of cotton farmers, filed suits against the cooperative of which they were members under contract, alleging that they were fraudulently induced to join the cooperative. Plaintiffs’ agreements with the cooperative provided for the arbitration of all disputes under the Federal Arbitration Act (FAA). The cooperative filed a motion to stay the litigation and a motion to compel arbitration. The trial court denied the motions, concluding that the parties’ arbitration agreement was unconscionable. The court of appeals affirmed, reasoning that the agreements were unconscionable because they forced the farmers to “forego substantive rights and remedies afforded by statute.” The Supreme Court reversed, holding that the limitation of statutory remedies was insufficient to defeat arbitration under the FAA. Remanded. View "Venture Cotton Coop. v. Freeman" on Justia Law

After Plaintiff purchased a used yacht, the yacht’s starboard engine failed beyond repair. Plaintiff sued Defendant-manufacturer, alleging several causes of action, including breach of the implied warranty of merchantability. The jury found Defendant liable only on the implied warranty claim. The trial court granted Defendant’s motion for judgment notwithstanding the verdict because Plaintiff was a subsequent purchaser of the used yacht and because Defendant disclaimed any implied warranty at the time of the first sale. The court of appeals reversed, holding that someone who knowingly buys used goods may still rely on an implied warranty from the manufacturer to the original buyer since the warranty passes with the goods. The Supreme Court affirmed, holding (1) Defendant could not rely on its purported express disclaimer of implied warranties issued at the first sale because it did not properly raise that defense in the trial court; (2) an implied warranty of merchantability, unless properly disclaimed, passes to subsequent buyers; and (3) therefore, Plaintiff was entitled to recover on his implied-warranty claim. View "MAN Engines & Components, Inc. v. Shows" on Justia Law

The Gobellans retained Law Firm to defend them and bring suit. Associate was assigned to the case. Associate later left Law Firm and took several clients, including Gobellans, with him. Law Firm sued Associate over client contingency fees, and later settled. Law Firm also sued Gobellans, and moved to compel the dispute to arbitration pursuant to an arbitration clause in the contingency fee agreement between Law Firm and Gobellans. The trial court and court of appeals denied Law Firm’s motion to compel arbitration, concluding that because Law Firm had litigated the fee issue with Associate, it waived its right to arbitrate claims stemming from its fee agreement with Gobellans. The Supreme Court reversed, holding (1) because Law Firm’s litigation conduct involved suing Associate, with whom it had no arbitration agreement, and filing limited pleadings against Gobellans, the conduct did not substantially invoke the litigation process against Gobellans or prejudice them; and (2) thus, Law Firm did not waive its right to arbitrate its dispute with Gobellans. View "Hodges, LLP v. Gobellan" on Justia Law

Plaintiff and Defendant were competitors. Plaintiff sued Defendant for tortious interference with Plaintiff’s non-solicitation agreements with employees. Five days after receiving a settlement offer from Defendant, Plaintiff filed its designation of expert witnesses. After Defendant filed its own expert designations, Plaintiff sent a letter “accepting” Defendant’s settlement offer. Defendant refused to pay the previously agreed-to amount based on fraudulent inducement and failure of consideration. Plaintiff amended its pleadings to assert a breach of contract claim based on the alleged settlement agreement. The trial court granted Plaintiff’s summary judgment motion on the breach of contract claim. The court of appeals reversed, concluding that no settlement agreement existed because Plaintiff had not accepted all of the offer’s material terms. The Supreme Court reversed, holding that the evidence established that Plaintiff accepted Defendant’s offer. Remanded. View "Amedisys, Inc. v. Kingwood Home Health Care, LLC" on Justia Law

Most of the employees at a La Porte unit (“Unit”) of E. I. du Pont de Nemours and Company (“DuPont”) were covered by a collective bargaining agreement (“CBA”). When DuPont announced plans to spin off part of its operations, including the Unit, into a wholly owned subsidiary, DuPont Textiles and Interiors (“DTI”), almost all of the Unit employees moved to DTI, even though the CBA gave the employees the right to transfer to other DuPont jobs. DuPont subsequently sold DTI to Koch Industries, which reduced the former DuPont employees’ compensation and retirement benefits. Several of the former DuPont employees sued DuPont for fraudulently inducing them to terminate their employment and accept employment with DTI by misrepresenting that DTI would not be sold. The Fifth Circuit Court of Appeals certified questions of law to the Texas Supreme Court, which answered by holding (1) at-will employees cannot bring an action against their corporate employer for fraud that is dependent on continued employment; and (2) employees covered under a cancellation-upon-notice CBA that limits the employer’s ability to discharge its employees only for just cause cannot bring Texas fraud claims against their employer based on allegations that the employer fraudulently induced them to terminate their employment. View "Sawyer v. E.I. du Pont de Nemours & Co." on Justia Law

Respondents filed claims against Petitioners relating to certain oil and gas ventures. At issue in this case was Respondents’ assignment claim, which an involved an agreement between Respondents and Petitioners for Respondents to pay a portion of drilling and operating costs in exchange for an assignment of a partial working interest in producing wells. After a bench trial, the trial court largely ruled for Respondents and awarded them $35,000 in attorney’s fees. The Supreme Court modified Respondents’ recovery on appeal and remanded for the trial court to redetermine the attorney’s fee award. On remand, the trial court awarded Respondents $30,000 in attorney’s fees. The Supreme Court reversed, holding that no legally sufficient evidence supported the amount of the attorney’s fee award because Respondents offered no evidence of the time expended on particular tasks as required via the lodestar method. Remanded. View "Long v. Griffin" on Justia Law

In this oil and gas billing dispute, Plaintiffs sued Defendant for, inter alia, breach of a joint operating agreement. Defendant counterclaimed and prevailed on its counterclaim. The trial court awarded Defendant prejudgment interest, but the court of appeals remanded to recalculate prejudgment interest. On remand, the trial court determined that the record had to be reopened, but rather than obtain the additional evidence, Plaintiff waived its claim for prejudgment interest. The trial court then awarded Defendant postjudgment interest from the date of its original, erroneous judgment. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in determining that new evidence was needed; but (2) because the remand necessitated reopening the record for additional evidence, postjudgment interest must accrue from the final judgment date rather than the original judgment date. Remanded. View "Long v. Castle Tex. Prod. Ltd. P’ship" on Justia Law

Crosstex Energy Services, LP hired Pro Plus, Inc. as the principal contractor to construct a natural gas compression station. Crosstex sued Pro Plus after an explosion occurred at the station, causing $10 million in property damage. The parties entered an agreement to move expert designation dates beyond the limitations period, but after limitations ran, Pro Plus filed a motion to dismiss because Crosstex had not filed a certificate of merit with its original petition as required by Tex. Civ. Prac. & Rem. Code Ann. 150.002. The trial court denied the motion and granted Crosstex an extension to file the certificate. The court of appeals reversed. The Supreme Court affirmed, holding (1) the court of appeals did not err in asserting jurisdiction over Pro Plus’s interlocutory appeal of the extension order; (2) section 150.002’s “good cause” extension is available only when a party filed suit within ten days of the end of the limitations period, and therefore, Crosstex could not claim protection from the good cause extension; and (3) a defendant’s conduct can waive the plaintiff’s certificate of merit requirement, but Pro Plus’s conduct did not constitute waiver. View "Crosstex Energy Servs. L.P. v. Pro Plus, Inc." on Justia Law

When Tyco Valves & Controls, L.P. decided to close one of its facilities located in Houston, Tyco offered certain employees retention agreements providing that, if the employees remained with the company through the facility’s closure, they would receive severance payments in the event they were not offered comparable employment with Tyco. After Tyco sold one of the production units located in the facility to another company, Plaintiffs, several former employees who had worked in that unit and been denied severance, filed a breach of contract action against Tyco. The trial court ruled in favor of the employees and awarded the severance pay. The court of appeals reversed. The Supreme Court affirmed, holding that the Employee Retirement Income and Security Act of 1974 preempted Plaintiffs’ breach-of-contract claims. View "Arsenio Colorado v. Tyco Valves & Controls, L.P." on Justia Law

James Olis, a former officer of Dynegy, Inc., was indicted on multiple counts of securities fraud, wire fraud, and conspiracy. Olis hired attorney Terry Yates to defend him in the federal criminal investigation and a civil investigation conducted by the SEC. Olis told Yates that Dynegy would be paying his legal fees. Dynegy's legal department orally confirmed that Dynegy would pay Olis's legal fees. Yates later filed suit against Dynegy to recover his unpaid attorney's fees, asserting claims for breach of contract and fraudulent inducement. The jury returned a verdict for Yates. At issue on appeal was whether Dynegy was entitled to judgment in its favor based on its affirmative defense of statute of frauds. The court of appeals reversed. The Supreme Court reversed and rendered a take-nothing judgment in favor of Dynegy, holding (1) the statute of frauds rendered the oral agreement between Dynegy and Yates unenforceable, and therefore, Yates could not recover under his breach of contract claim; and (2) Yates's claim for benefit-of-the-bargain damages pursuant to his alternative fraudulent inducement action was barred.View "Dynegy, Inc. v. Yates " on Justia Law