Justia Texas Supreme Court Opinion Summaries

Respondent injured his back while working, and his employer's workers' compensation insurer, Texas Mutual Insurance Company (TMIC), accepted the injury as compensable. Three years later when it was discovered that Respondent had herniated lumbar intervertebral discs, TMIC disputed whether they were causally related to the original injury. The Texas Department of Insurance Division of Workers' Compensation determined that the disc herniations were related to the original injury and ordered TMIC to pay medical benefits, which it did. Respondent later sued TMIC for damages caused by its delay in paying benefits. The trial court rendered judgment for Respondent, and the court of appeals affirmed. Based on the Court's recent decision in Texas Mutual Insurance Co. v. Ruttiger, the Supreme Court reversed and rendered judgment for TMIC. View "Tex. Mut. Ins. Co. v. Morris" on Justia Law

In this employer retaliation case, a broad-form jury question allowed the jury to find liability based on a legal theory that was jurisdictionally barred and thus could not support liability. The trial court entered a judgment reinstating Employee to her position and awarding her damages and attorney's fees. Employer appealed, arguing that the jury charge allowed a finding of liability based on invalid legal theories. The court of appeals concluded that Employer waived its objection. The Supreme Court reversed, holding (1) Employer properly preserved its objection; and (2) because the Court could not determine whether the jury relied on the invalid theory, the case was remanded for a new trial. View "Tex. Comm'n on Human Rights v. Morrison" on Justia Law

An employee (Employee) of the Austin Independent School District (AISD), a self-insured governmental entity, was injured on the job. AISD acknowledged that Employee had been injured but disputed whether the compensable injury extended to two alleged conditions. A hearing officer sided with Employee on the contested issues, as did the administrative appeals panel. In the district court, Employee filed a counterclaim seeking attorney fees. AISD filed a nonsuit, leaving only the counterclaim for fees. After a jury trial, Employee won a judgment on the verdict that included pre-nonsuit and post-nonsuit attorney fees. The court of appeals found (1) the evidence was sufficient to support the pre-nonsuit fee award, but (2) the post-nonsuit fee award could not stand. AISD brought a petition for review in the Supreme Court, arguing for the first time that governmental immunity from suit barred the award of attorney fees. The Supreme Court reversed in part, holding (1) the defense of sovereign immunity may be raised for the first time on appeal; and (2) AISD was immune from Employee's claim for attorney fees. View "Manbeck v. Austin Indep. Sch. Dist." on Justia Law

The issue in this case was whether an appellate court has jurisdiction over an appeal from a trial court order confirming an arbitration award in part and vacating the award in part based on the existence of unresolved questions of law or fact necessary to a ruling, yet the trial court did not expressly direct a rehearing. The court of appeals held that it did not have jurisdiction over the appeal, holding (1) the judgment was not final because it did not contain finality language or otherwise state that it was a final judgment and necessarily contemplated resolution of the remaining issues by way of a rehearing, and therefore, the appeal was interlocutory; and (2) no statute permitted an appeal in this case. The Supreme Court affirmed and, for different reasons, dismissed the appeal for want of jurisdiction, holding (1) the appeal was interlocutory; (2) the Texas Arbitration Act did not provide jurisdiction over the interlocutory appeal; and (3) there is no jurisdiction over arbitration awards that are incomplete unless, under certain circumstances, the parties file a writ of mandamus, which neither party here filed. View "Bison Bldg. Materials, Ltd. v. Aldridge" on Justia Law

At issue in this interlocutory appeal was whether the claims of an employee against his employer, both of whom were health care providers, alleging injuries arising out of inadequate training, supervision, risk-mitigation, and safety in a mental health facility, constituted health care liability claims (HCLCs) under the Texas Medical Liability Act (Act). Employer filed a motion to dismiss on the grounds that Employee's claims constituted HCLCs under the Act and that Employee had not served an expert report on Employer as required under the Act. The trial court denied Employer's motion. The trial court affirmed. The Supreme Court reversed, holding (1) Employee here was properly characterized as a "claimant" under the Act and his allegations against his nonsubscribing Employer were health care and safety claims under the Act's definition of HCLCs, requiring an expert report to maintain his lawsuit; and (2) the Act does not conflict with the Texas Workers' Compensation Act. Remanded. View "Tex. W. Oaks Hosp., LP v. Williams " on Justia Law

After Employer fired her, Plaintiff filed suit, alleging that she was discriminated against based on her race, national origin, age, and gender. Employer filed a plea to the jurisdiction, arguing that Plaintiff's pleadings failed to establish a prima facie case of discrimination because Plaintiff was replaced by another Mexican-American woman who was three years older than Plaintiff. The trial court denied Employer's plea. The court of appeals affirmed in part and reversed in part, holding that the plea should have been granted on the age-discrimination, as replacement by an older worker was not fatal to Plaintiff's claim. The Supreme Court reversed and dismissed the suit, holding (1) to establish a prima facie case of age discrimination under the Texas Commission on Human Rights Act (TCHRA), a plaintiff in a true replacement case must show she was (i) a member of the protected class, (ii) qualified for her employment position, (iii) terminated by the employer, and (iv) replaced by someone younger; and (2) because Plaintiff here was replaced by an older worker, she failed to allege a prima facie case, and the trial court should have granted Defendant's plea to the jurisdiction. View "Mission Consol. Indep. Sch. Dist. v. Garcia" on Justia Law

An injured employee (Employee) sought workers' compensation benefits for a work-related injury. A claims adjuster with Employer's workers' compensation insurer's (Insurer) third party administrator denied the claim. The Division of Workers' compensation determined that Employee was entitled to medical and temporary income benefits. Employee subsequently brought a bad faith action against Insurer, its third party administrator, and the claims adjuster (Defendants). During discovery, Employee sought communications made between Insurer's lawyer and Employer during the administrative proceedings. Defendants argued that the attorney-client privilege protected the communications. The trial court held that the privilege did not apply. The court of appeals subsequently denied mandamus relief. The Supreme Court affirmed, holding that the attorney-client privilege did not protect the communications between Insurer and its insured. View "In re XL Specialty Ins. Co." on Justia Law

Employee suffered an injury during the course of his employment that was compensable under the Texas Workers' Compensation Act. Petitioner insurance company provided workers' compensation coverage to Employee's employer. Petitioner disputed the impairment rating of twenty percent assigned by the doctor in the administrative proceedings. A hearing officer issued a decision finding that Employee had an impairment rating of twenty percent. The Division of Workers' Compensation upheld the decision. Petitioner appealed. The trial court granted Employee's plea to the jurisdiction and dismissed the case. The court of appeals affirmed. At issue on appeal was whether a reviewing court lacks subject matter jurisdiction to resolve an impairment rating appeal if the only rating presented to the agency was invalid. The Supreme Court reversed, holding that the absence of a valid impairment rating does not deprive the court of jurisdiction. Remanded. View "Am. Zurich Ins. Co. v. Samudio" on Justia Law

The parties to the appeal disagreed about whether an employer who self funded a health-benefit plan for its employees was an "insurer" under the Texas Insurance Code, and therefore should be treated as a reinsurer when purchasing stop-loss insurance. The court of appeals concluded that an employer's self-funded plan was clearly an insurer under the Code and that a plan's purchase of stop-loss insurance was also clearly reinsurance beyond the regulatory scope of the Texas Department of Insurance. The court accordingly reversed the trial court's judgment, which held that the agency's regulation of the stop-loss policies at issue as direct insurance. Because the regulatory agency did not clearly err in its regulation of these stop-loss policies, however, the court reversed the court of appeals' judgment and rendered judgment for the agency. View "TX Dept. of Ins., et al. v. American National Ins. Co., et al." on Justia Law

Plaintiff brought a wrongful termination claim against his employer under Sabine Pilot Service, Inc. v. Hauck, seeking lost wages, mental anguish damages, and exemplary damages. This case required the court to clarify the nature and scope of the cause of action for wrongful termination of an employee for refusing to perform an illegal act that the court recognized in Sabine Pilot. At issue was whether a plaintiff in a Sabine Pilot action could recover punitive damages, and if so, what must be shown as to a prerequisite for those damages. The court agreed with the court of appeals' conclusion that a Sabine Pilot cause of action sounded in tort and allowed punitive damages upon proper proof. However, because the court held that plaintiff failed to present legally sufficient evidence of malice relating to his firing, the court reversed the court of appeals' judgment insofar as it affirmed the award of exemplary damages. View "Safeshred, Inc. v. Martinez, III" on Justia Law