Justia Texas Supreme Court Opinion Summaries

This case arose from respondent's injury on the job and the arbitration agreement he signed as a condition of his employment. At issue was whether an appellate court had 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. Because the order left significant factual and legal issues open for further determination, it was interlocutory and not appealable unless authorized by statute. Accordingly, the court of appeals and the court did not have jurisdiction over the interlocutory appeal. View "Bison Building Materials, Ltd., v. Aldridge" on Justia Law

Plaintiff and her son were injured when her car was struck by a pickup truck driven by Edward Cantu. MCAA employed Cantu and Puckett owned the truck. Cantu's negligence was stipulated. The jury found that, although MCAA was his employer, Cantu drove the vehicle for Puckett's benefit. The jury found that MCAA, as Cantu's employer, had the right to direct the details of his work. It also found that Cantu was subject to Puckett's control "as to the details of the mission" when the accident occurred. The trial court rendered judgment for plaintiff. The court of appeals remanded for a new trial, holding that a jury could not logically find MCAA and Puckett to have simultaneously controlled Cantu's conduct, as the trial court had instructed the jury that Cantu could not have been an employee of both. But the jury also found that MCAA was subject to Puckett's control and was on a mission for Puckett's benefit - which comprised the elements of a principal-agent relationship. MCAA was vicariously liable for its employee's negligence; Puckett as principal was responsible for its agent's conduct. Because it was able to reconcile the jury's answers on that agency theory, the court reversed the court of appeals' judgment. View "Arvizu, et al. v. The Estate of George Puckett" on Justia Law

Rafael Casados suffered a fatal, work-related injury while working for two employers that both had workers' compensation coverage. Casados' parents sued one of the employers. At issue was whether workers' compensation was the exclusive remedy to Casados' parents, which would bar their suit against Port Elevator. Because Port Elevator had a workers' compensation policy, Casados was an employee, he suffered a work-related injury, and the jury failed to find Port Elevator grossly negligent, the Texas Workers' Compensation Act (TWCA), Tex. Lab. Code 406, provided that the exclusive remedy was against the employer's insurer - not the employer. Accordingly, the claim at issue in this appeal was barred. The court reversed the judgment of the court of appeals and rendered judgment for Port Elevator. View "Port Elevator-Brownsville, L.L.C. v. Casados, et al." on Justia Law

This matter arose out of a dispute over whether the City of Dallas paid its firefighters and police officers in accord with a 1979 ordinance adopted pursuant to a voter-approved referendum. Claiming the City had not properly paid them, some firefighters and police officers brought a class action asserting breach of contract claims and seeking a declaratory judgment. For the reasons set out in City of Dallas v. Albert, the court concluded that: (1) the ordinance's adoption by means of referendum did not result in the City's loss of immunity from suit; (2) the City had immunity from suit as to the declaratory judgment action; (3) by non-suiting its counterclaim the City did not reinstate immunity from suit as to the Officers' claims that were pending against the City when it non-suited the counterclaim; and (4) the case must be remanded for the trial court to consider whether the Legislature waived the City's immunity by amending the Local Government Code. View "City of Dallas v. Martin, et al." on Justia Law

Firefighters for the City of Baytown sued the City claiming that it improperly calculated pay for certain assignments in violation of the Firefighter and Police Civil Services Act. Here, the firefighters' claims for back pay and related damages for improper calculation of pay for assignments performed in the past were the type of retrospective relief that the court held barred by governmental immunity in City of El Paso v. Heinrich and City of Houston v. Williams. In Heinrich, the court noted however, that the Legislature could authorize retrospective relief. The firefighters asserted that the Legislature had done so with Local Government Code sections 271.151-.160, enacted during the pendency of this appeal. In addition to remanding to permit the firefighters to replead in light of Chapter 271, the court also remanded to permit the firefighters to replead in light of Heinrich and seek appropriate relief, if any, against the relevant city officials. View "Lowell, et al. v. Baytown, et al." on Justia Law

This case arose when plaintiff filed suit against its former employee and the employee's new employer for breach of contract and breach of fiduciary duty, claiming, among other things, that the new employer had solicited and accepted business from clients and prospects of plaintiff who were serviced by the new employer or where the new employer supervised the solicitation of activities related to the client or potential client. At issue on appeal was whether a covenant not to compete signed by a valued employee in consideration for stock options, designed to give the employee a greater stake in the company's performance, was unenforceable as a matter of law because the stock options did not give rise to an interest in restraining competition. The court held that, under the terms of the Covenants Not to Compete Act, Tex. Bus. & Com. Code ch. 15, the consideration for the noncompete agreement was reasonably related to the company's interest in protecting its goodwill, a business interest the Act recognized as worthy of protection. The noncompete was thus not enforceable on that basis. The court reversed the court of appeals' judgment and remanded to the trial court for further proceedings. View "Marsh USA Inc., et al. v. Cook" on Justia Law

Petitioner filed suit against respondent for breach of contract and breach of fiduciary duty. Respondent had been employed by petitioner since 1983 and rose to become a managing director. In 2005, respondent signed a Non-Solicitation Agreement and notice form stating that he wanted to exercise a stock option to acquire 3000 shares of stock of petitioner's parent company. At issue was whether a covenant not to compete signed by a valued employee in consideration for stock options, designed to give the employee a greater stake in the company's performance, was unenforceable as a matter of law because the stock options did not give rise to an interest in restraining competition. The court held that, under the terms of the Covenants Not to Compete Act (Act), Tex. Bus. & Com. Code 15.50, 52, the consideration for the noncompete agreement (stock options) was reasonably related to the company's interest in protecting its goodwill, a business interest the Act recognized as worthy of protection. Therefore, the noncompete was not unenforceable on that basis. Accordingly, the court reversed the court of appeal's judgment and remanded to the trial court for further proceedings. View "Marsh USA Inc., et al. v. Cook" on Justia Law

Marcos Guerra was buried at Mont Meta Memorial Park cemetery in a plot that had been sold to someone else. When his family refused the cemetery's request that it be allowed to move the body to another burial plot, the cemetery did so anyway. Guerra's family members subsequently sued defendants, the corporation that owned and operated the cemetery and its parent corporation. At issue was whether the evidence was sufficient to support jury findings that defendants were liable for actions of the cemetery's employees and whether plaintiffs suffered compensable mental anguish because Guerra's body was disinterred and moved to another grave without permission. Also at issue was whether evidence of other lawsuits against defendants was properly admitted. The court held that there was legally insufficient evidence to support either the liability findings or mental anguish findings. The court also held that the trial court erred by admitting evidence of other lawsuits, verdicts, and judgments and that such evidence was harmful and required the case to be remanded for a new trial. Accordingly, the court reversed the judgment of the court of appeals, rendered judgment in part, and remanded for a new trial in part. View "Service Corp. Int'l, et al. v. Guerra" on Justia Law

Respondent filed a sex discrimination suit against petitioner alleging violations of the Texas Commission on Human Rights Act, Tex. Lab. Code 21.001-.556, where petitioner terminated its employment of respondent citing as the basis for its decision a reduction in force due to worsening business conditions. The parties sought arbitration and petitioner appealed the arbitrator's reward. At issue was whether the Texas General Arbitration Act ("TAA"), Tex. Civ. Prac. & Rem. Code 171.001-.098, precluded an agreement for judicial review of an arbitration award for reversible error, and if not, whether the Federal Arbitration Act ("FAA"), 9 U.S.C. 1-16, preempted enforcement of such an agreement. The court held that the TAA presented no impediment to an agreement that limited the authority of an arbitrator in deciding a matter and thus allowed for judicial review of an arbitration award for reversible error. The court also held that the FAA did not preempt enforcement of an agreement to expanded judicial review of an arbitration award enforceable under the TAA. The court further held that, on remand, the court of appeals must determine whether the record was sufficient to review petitioner's complaints. Therefore, the judgment of the court of appeals must be reversed and the case remanded to that court for consideration of the merits of petitioner's challenges to the arbitration award.