Justia Texas Supreme Court Opinion Summaries

In this case, the Supreme Court articulated with greater clarity the standards governing whether an act of spoliation has occurred and the limits of a trial court’s discretion to impose certain remedies upon a finding of spoliation. In the underlying slip-and-fall premises-liability case, the defendant-premises owner retained a portion of surveillance video footage of the plaintiff’s fall but allowed additional footage to be automatically erased. The trial court submitted a spoliation instruction to the jury and allowed the jury to decide whether spoliation occurred. The jury rendered a verdict in favor of the plaintiff. The Supreme Court reversed, holding that the trial court abused its discretion in imposing the severe sanction of a spoliation instruction. Remanded for a new trial. View "Brookshire Bros., Ltd. v. Aldridge" on Justia Law

A family from Mexico hired Jose Marciel, a “coyote,” to transport them to Houston or New Orleans. Marciel collected the family at a house in Texas, and, before dawn, arrived at the private Jones Ranch. An employee of the ranch operator stopped Maciel to ask why he had entered the property, after which Maciel fled at high speed. The vehicle rolled over, killing the family. Respondents, the deceased mother’s parents, sued the ranch’s operators and an employee (collectively, Petitioners), alleging wrongful death claims, including negligence and gross negligence. The trial court granted summary judgment for Petitioners. The court of appeals reversed in part. The Supreme Court reversed in part and affirmed in part, holding (1) the trial court erred in granting a traditional summary judgment based on the common law unlawful acts doctrine because the statutory comparative responsibility scheme abrogated this doctrine; (2) a land occupier owes only a duty to avoid injuring a trespasser wilfully, wantonly, or through gross negligence, and therefore, Respondents’ claim for simple negligence must fail as a matter of law; and (3) as to gross negligence, the trial court properly granted a no-evidence summary judgment motion because Respondents failed to raise a genuine issue of material fact. View "Boerjan v. Rodriguez" on Justia Law

Jimmy Carty died in an accident during his employment for the state. The workers’ compensation carrier for state employees (carrier) began paying death benefits to Christy, Jimmy’s wife, and the couple’s three minor children. Christy, individually, as representative of her deceased husband’s estate, and as next friend of the couple’s children, brought suit against two defendants. The Cartys settled with the defendants. The district court subsequently calculated the carrier's reimbursement and apportioned the remainder of the settlement funds among Christy and the children “in the same ratio as they received death benefits.” The carrier appealed, challenging the apportionment. The court of appeals certified to the Supreme Court the question of “how a net recovery in excess of the amount of benefits paid by the workers’ compensation carrier should be apportioned among beneficiaries when multiple beneficiaries recover from a third-party tortfeasor.” The Supreme Court answered that when multiple beneficiaries recover compensation benefits through the same covered employee, the workers’ compensation carrier’s right to a third-party settlement is determined by treating the recovery as a single, collective recovery rather than separate recoveries by each beneficiary. View "State Office of Risk Mgmt. v. Carty" on Justia Law

A corporation invited guests to a business retreat at the corporation’s expense at a lodge near the Gulf of Mexico. The lodge provided the guests with bay fishing from small boats. The corporation provided alcoholic beverages on the boats at the guests’ request. After one guest spent some time on the boat, returned to the lodge, and left to drive home, the guest struck a motorcycle ridden by the plaintiffs, who were severely injured. The plaintiffs sued the corporation, alleging that it negligently allowed the guest to drink excessively. Because Texas law does not recognize such social host liability, the plaintiffs asserted that federal maritime law applied in this case because, before the accident, the guest became intoxicated while on the fishing boat. The court of appeals concluded that maritime law applied. The Supreme Court reversed, holding that, under the tests set forth by the U.S. Supreme Court in Jerome B. Grubart, Inc. v. Great Lakes Dredge & Dock Co., the action did not fall within admiralty jurisdiction. View "Schlumberger Tech. Corp. v. Arthey" on Justia Law

An owner contracted with an Architect to prepare plans and specifications for the construction of a light rail. A General Contractor was awarded the contract to construct the project. The Architect and General Contractor had no contract with each other. Because the Architect’s plans were full of errors, the General Contractor lost nearly $14 million on the project. The General Contractor filed a tort suit against the Architect, alleging negligent misrepresentation. The trial court rendered judgment for the General Contractor for $2.25 million plus interest. The Architect appealed, arguing that the economic loss rule barred the General Contractor’s claim. The Supreme Court reversed, holding that the economic loss rule applied in this case to preclude the General Contractor from recovering delay damages from the Architect. View "LAN/STV v. Martin K. Eby Constr. Co., Inc." on Justia Law

Plaintiff, a patron of the Graham Central Station nightclub, was assaulted by other patrons of the club. Plaintiff sued Graham Central Station, Inc. (GCS), the nightclub’s purported owner, alleging that GCS failed to provide adequate security to protect Plaintiff. The trial court rendered judgment for Plaintiff and awarded him $450,000 for pain and suffering and mental anguish. GCS appealed, arguing that Plaintiff sued the wrong party and that the evidence was insufficient to support the damages award. The court of appeals reduced Plaintiff’s damages to $249,000 and otherwise affirmed. The Supreme Court reversed the court of appeals’ judgment and rendered judgment in GCS’s favor, holding that the evidence supporting a finding that GCS owned the nightclub was legally insufficient, and therefore, there was insufficient evidence that GCS owed a duty to Plaintiff. View "Graham Cent. Station, Inc. v. Pena" on Justia Law

Keystone-Texas Property Holding Corporation owned the Rivercenter Mall and the ground beneath the San Antonio Marriott Riverwalk hotel. Keystone leased the hotel land to Petitioners, who owned and operated the hotel. In 2004, Keystone put the two properties up for sale. After Keystone found a prospective buyer, Petitioners informed Keystone they were interested in buying the land and were not ready to waive their rights under the lease. The deal to sell the properties fell through, and Keystone sued Petitioners for actions Keystone believed scuttled the deal. A jury found for Keystone on all issues and awarded damages for slander of title and tortious interference with a contract. The Supreme Court reversed, holding that there was no evidence Petitioners caused any damages to Keystone. View "HMC Hotel Props. II Ltd. P’ship v. Keystone-Texas Prop. Holding Corp." on Justia Law

Plaintiff brought suit in state court against two county sheriff’s department deputies stemming from the officers’ conduct incident to Plaintiff’s arrests. Plaintiff then brought suit in federal court against the county and county sheriff alleging the same tort claims she had made against the officers, based on vicarious liability principles, and alleging violations of her civil rights. In the state court action, the trial court denied the officers’ motion for summary judgment under the Texas Tort Claims Act’s (TTCA) election-of-remedies provision. The Supreme Court reversed and rendered judgment in favor of the officers, holding (1) Plaintiff’s suit on the officers was based on the conduct within the general scope of the officers’ employment and could have been brought under the TTCA against the government, and therefore, Plaintiff’s suit was against the officers in their official capacity only; and (2) because the officers were sued in their official capacities, they were entitled to dismissal under the TTCA’s election-of-remedies provision. View "Alexander v. Walker" on Justia Law

Russell Gordon was stopped by City of Watauga police officers and arrested. Gordon subsequently sued the City for injuries to his wrists caused by the officers' use of handcuffs. The City filed a plea to the jurisdiction, asserting that it was immune from suit under the intentional-tort exception to the Tort Claims Act’s governmental immunity waiver. The Act waives sovereign immunity for certain negligent conduct but does not waive immunity for claims arising out of intentional torts, such as battery. The court of appeals affirmed, concluding that the underlying claim was for negligence, and therefore, the City was not entitled to immunity. The Supreme Court reversed and dismissed the case, holding that the underlying claim was for battery, not negligence, and the City’s governmental immunity had not been waived for this intentional tort. View "City of Watauga v. Gordon" on Justia Law

Petitioner filed an action in state court against Respondent, a county sheriff’s deputy, arising from an incident in which Petitioner was arrested at her home. Petitioner subsequently filed an action in federal court arising out of the same incident against the county and the former county sheriff. The two cases were consolidated in federal court. The federal court dismissed the federal claims against the county and the sheriff and then remanded the tort claims against Respondent. The trial court denied Respondent's motion for summary judgment. The court of appeals reversed, concluding that Petitioner’s suit against the county in federal court entitled Respondent to dismissal under Tex. Civ. Prac. & Rem. Code 101.106(a). The Supreme Court affirmed but for different reasons, holding that Petitioner’s claims against Respondent should have been dismissed under subsection (f) of the Texas Tort Claims Act’s election-of-remedies provision. View "Stinson v. Fontenot" on Justia Law