Justia Texas Supreme Court Opinion Summaries

Shortly after the City of Houston enacted a drainage-free ordinance, Houston Belt & Terminal Railway, BNSF Railway, and Union Pacific Railway (collectively, the Railroads) received notices of proposed charges for their properties in Houston. Daniel Krueger, the City’s Director of Public Works and Engineering, determined that the properties were “benefitted” and thus subject to drainage charges and determined that the Railroads should pay roughly $3 million based on their benefitted properties’ “impervious surface” area. The Railroads filed suit against the City and Krueger in his official capacity, alleging ultra vires claims against Krueger and seeking prospective injunctive relief. The trial court sustained the City’s plea to the jurisdiction as to the Railroads’ ultra vires claims based on governmental immunity. The court of appeals affirmed in part and reversed in part, concluding that the Railroads pleaded a viable ultra vires claim challenging Krueger’s determination that their properties were benefitted but that the railroads’ challenge to Krueger’s “impervious surface” determination did not fall within the ultra vires exception. The Supreme Court reversed in part, holding that the Railroads’ pleadings affirmatively alleged that Krueger acted “without legal authority” in both his “benefitted property” and “impervious surface” determinations, and thus the pleadings alleged viable ultra claims as to each. View "Houston Belt & Terminal Ry. Co. v. City of Houston" on Justia Law

In 2008, the Railroad Commission of Texas issued orders to plug a number of inactive offshore wells operated in the Gulf of Mexico. Gulf Energy Exploration Corporation was the lessee of the offshore area that included one of wells subject to the plugging order. The Commission and Gulf Energy reached an agreement that the Commissioner would delay plugging this well. A few months later Gulf Energy discovered that the well was plugged. Gulf Energy sued the Commission with legislative permission. The jury returned a favorable verdict on Gulf Energy’s negligence and breach-of-contract claims. The court of appeals affirmed. The Supreme Court reversed, holding (1) the trial court erred in refusing to submit a jury question on a statutory good-faith defense; and (2) a question of fact existed as to whether the Commission and Gulf Energy entered into a binding contract before the well was plugged. Remanded for a new trial. View "R.R. Comm’n of Texas v. Gulf Energy Exploration Corp." on Justia Law

In 2004, Employee was working for Employer when she fell, injuring her left knee and back. In 2009, Employee filed a claim for lifetime income benefits (LIBs) pursuant to section 408.161 of the Texas Workers’ Compensation Act claiming that her 2004 injury caused the total loss of use of both her feet at or above the ankle and that the loss of use was permanent. A hearing officer with the Division of Workers’ Compensation determined that Employee was not entitled to LIBs. The district court reversed and awarded LIBs. The court of appeals affirmed. The Supreme Court reversed and rendered judgment denying Employee’s claim for LIBs, concluding that the court of appeals erred in determining that the evidence was sufficient to support the trial court’s judgment. View "Dallas Nat’l Ins. Co. v. De La Cruz" on Justia Law

McGinnes Industrial Waste Corporation dumped pulp and paper mill waste sludge into disposal pits near the San Jacinto River in Pasadena, Texas (the site). After environmental contamination was discovered at the site, the Environmental Protection Agency (EPA) instituted superfund cleanup proceedings under the federal Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). During the period that McGinnes was dumping waste at the Site, it was covered by standard-form commercial general liability (CGL) insurance policies issued by Phoenix Insurance Company and Travelers Indemnity Company (together, the Insurers). McGinnes requested a defense in the EPA proceedings from the Insurers. The Insurers refused, determining that the proceedings were not a “suit” under the policy. McGinnes sued the insurers in federal court seeking a declaration that the policies obligated them to defend the EPA’s CERCLA proceedings. The district court granted the Insurers’ motion for partial summary judgment on the duty-to-defend issue. The U.S. Court of Appeals for the Fifth Circuit certified a question regarding the issue to the Texas Supreme Court. The Supreme Court answered that “suit” in the CGL policies at issue must also include CERCLA enforcement proceedings by the EPA. View "McGinnes Indus. Maint. Corp. v. Phoenix Ins. Co." on Justia Law

Petitioners in this case were deaf inmates housed in a unit of the Texas Department of Criminal Justice (TDCJ). Petitioners sued TDCJ’s executive director, asserting that he violated the Texas Human Resources Code by failing reasonably to accommodate their impairment. Petitioners relied on the ultra vires exception to sovereign immunity as a basis for showing that the trial court had jurisdiction. The trial court granted a temporary injunction ordering TDCJ to make certain accommodations. The court of appeals reversed and dismissed the case for want of jurisdiction, holding that TDCJ prison facilities are not “public facilities” under the Code, and therefore, Defendant could not have acted ultra vires by failing to comply with its provisions. The Supreme Court affirmed, holding that the court of appeals did not err in holding that TDCJ prisons are not “public facilities” under the Code and that Petitioners failed to show Defendant acted ultra vires. View "Beeman v. Livingston" on Justia Law

Greater Houston Partnership (GHP) is a nonprofit corporation providing economic development services to the City and other clients pursuant to quid pro quo contracts. A Houston area resident submitted to GHP a request seeking a copy of GHP’s check register. The resident claimed that GHP is an organization that spends or is supported in whole or in part by public funds, and therefore, GHP is subject to the Texas Public Information Act (TPIA) in the same manner as a governmental body. GHP did not disclose the requested information, claiming that it did not qualify as a “governmental body” under the TPIA because the public funds it received were compensation for services provided to the City of Houston pursuant to a contract. The Attorney General concluded that GHP was subject to the TPIA’s disclosure requirements. The trial court agreed, and the court of appeals affirmed the trial court. The Supreme Court reversed, holding that GHP is not a “governmental body” under the TPIA because it is not wholly or partially sustained by public funds. View "Greater Houston P’ship v. Paxton" on Justia Law

Certain provisions of the Texas Occupations Code and Texas Commission of Licensing and Regulation rules promulgated pursuant to that Code require eyebrow threaders to undergo 750 hours of training in order to obtain a license before practicing commercial threading. Plaintiffs, several individuals practicing commercial eyebrow threading and the salon owners employing them, filed this declaratory judgment action asserting that, as applied to them, Texas’s licensing statutes and regulations violate the state Constitution’s due course of law provision. Specifically, Plaintiffs alleged that the number of hours required for a license to practice commercial eyebrow threading are not related to health or safety or to what threaders actually do. The trial court granted summary judgment for the State. The court of appeals affirmed. The Supreme Court reversed, holding that the large number of required hours that are not arguably related to the actual practice of threading, the associated costs of those hours, and the delayed employment opportunities while taking the hours make the licensing requirements as a whole reach the level of being so burdensome that they are oppressive in light of the governmental interest. View "Patel v. Dep’t of Licensing & Regulation" on Justia Law

This premises-liability case arose from the drowning deaths of a young father and his twin daughters at a man-made beach. The mother and surviving spouse of the decedents (Plaintiff) filed suit against the City of Texas City alleging that the deaths resulted from a peculiar risk of harm created by a confluence of artificial and natural conditions at the beach and that the the City was grossly negligent in failing to warn or protect the public against those dangers. In bringing suit against Texas City, Plaintiff averred that governmental immunity was waived. The City filed a plea to the jurisdiction, asserting that Plaintiff’s pleadings and evidence were insufficient to support jurisdiction. The trial court denied the jurisdictional plea. The court of appeals reversed and dismissed the claims for want of jurisdiction. At issue on appeal was whether there was evidence of the City’s liability to invoke the Texas Tort Claims Act’s waiver of governmental immunity, as limited by the recreational use statute. The Supreme Court affirmed, holding that Plaintiff failed to produce sufficient evidence to invoke the Texas Tort Claims Act’s waiver of immunity from suit. View "Suarez v. City of Texas City" on Justia Law

Candelario Lopez, who was hired by Interstate Treating to work on the installation of a gas processing plant, was transporting two other Interstate Treating employees to the job site when he died in an automobile accident. Lopez’s wife, Maximina Lopez, sought death benefits from Interstate Treating’s workers’ compensation insurance carrier, SeaBright Insurance Co. SeaBright denied coverage, concluding that Lopez was not acting in the course and scope of his employment at the time of the accident. A hearing officer, however, determined that Lopez was acting in the course and scope of his employment and ordered SeaBright to pay death benefits. The trial court affirmed the administrative decision. The court of appeals affirmed the trial court’s judgment. The Supreme Court affirmed, holding that Lopez was acting in the course and scope of his employment when he died, and Maximina was entitled to benefits. View "Seabright Ins. Co. v. Lopez" 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