Justia Texas Supreme Court Opinion Summaries

An employee, Sharon Dunn, was injured while working as an emergency-department nurse for East Texas Medical Center Athens (ETMC Athens), a nonsubscriber to the Texas workers’ compensation program. Dunn alleged that an emergency medical technician (EMT), who was not employed by ETMC Athens, negligently pushed a stretcher into her, causing a serious back injury. Dunn initially sued the EMT and his employer, but those claims were dismissed due to her failure to timely serve an expert report as required by the Texas Medical Liability Act. Dunn then amended her pleadings to assert negligence claims against ETMC Athens.The trial court granted ETMC Athens's motion to designate the EMT and his employer as responsible third parties under the Texas proportionate-responsibility statute. However, eleven months later, Dunn moved to strike the designations, arguing that her suit was an action to collect workers’ compensation benefits, to which the proportionate-responsibility statute does not apply. The trial court granted Dunn’s motion, and the court of appeals denied ETMC Athens’s petition for mandamus relief.The Supreme Court of Texas reviewed the case and concluded that the trial court abused its discretion by striking the designations. The court held that the proportionate-responsibility statute applies because Dunn’s negligence claim against ETMC Athens is not an action to collect workers’ compensation benefits under the Workers’ Compensation Act. The court also held that the Act does not prohibit nonsubscribing employers from designating responsible third parties and that there was sufficient evidence of the third parties’ responsibility. Consequently, the Supreme Court of Texas conditionally granted ETMC Athens’s petition for mandamus relief, ordering the trial court to vacate its order striking the designations. View "IN RE EAST TEXAS MEDICAL CENTER ATHENS" on Justia Law

Mara Lindsey was involved in a car accident where she was rear-ended by Carlos Pantoja, resulting in personal injuries. Lindsey sought compensation for her medical expenses and, after settling with Pantoja’s insurer for his policy limit of $50,000, she filed a claim with her own insurer, State Farm, under her underinsured motorist (UIM) policy. Dissatisfied with State Farm’s settlement offer of $689.58, Lindsey sued State Farm under the Uniform Declaratory Judgments Act (UDJA) for declarations regarding Pantoja’s liability, her damages, and her entitlement to UIM benefits. She also sued State Farm and its claims adjuster for Insurance Code violations, alleging bad faith in handling her claim.The trial court denied State Farm’s motions to abate the extracontractual claims and to quash the deposition notice of its corporate representative. The court of appeals denied State Farm’s mandamus petitions without substantive explanation. State Farm then petitioned the Supreme Court of Texas for mandamus relief.The Supreme Court of Texas held that the trial court abused its discretion by denying State Farm’s motions. The court ruled that extracontractual claims must be abated until the insured obtains a favorable judgment on the UIM coverage, as these claims are dependent on the right to receive UIM benefits. The court also held that discovery on extracontractual matters is improper before establishing entitlement to UIM benefits. Additionally, the court found that State Farm had demonstrated that the deposition of its corporate representative was not proportional to the needs of the case, given the lack of personal knowledge and the burden of the proposed discovery.The Supreme Court of Texas conditionally granted State Farm’s petition for writ of mandamus, ordering the trial court to vacate its previous orders and grant State Farm’s motions to abate the extracontractual claims and to quash the deposition notice. View "IN RE STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY" on Justia Law

A Colorado real estate investment trust sued a Texas hedge fund and its employees for damages caused by an allegedly defamatory article published under a pseudonym. The claims were dismissed in Colorado federal court for lack of personal jurisdiction. The trust then sued in Texas state court. The defendants moved to dismiss under the Texas Citizens Participation Act (TCPA) and for summary judgment based on collateral estoppel. The trial court granted both motions.The Court of Appeals for the Fifth District of Texas reversed the trial court's decision. It held that the trial court lacked authority to grant the TCPA motion after it was overruled by operation of law and that the defendants failed to conclusively establish that collateral estoppel barred the claims. The appellate court determined that the Colorado court's findings on personal jurisdiction did not preclude the Texas claims and that the addition of new defendants in Texas further demonstrated that the issues were not identical.The Supreme Court of Texas reviewed the case. It agreed with the appellate court that the defendants were not entitled to summary judgment on their collateral estoppel defense. However, it found that the appellate court erred in holding that the order granting the TCPA motion was void. The Supreme Court of Texas concluded that the trial court's error in granting the TCPA motion outside the statutory deadline was harmless because it occurred within the time frame in which the defendants could have appealed the denial by operation of law. The case was remanded to the appellate court to address the TCPA motion on its merits. View "FIRST SABREPOINT CAPITAL MANAGEMENT, L.P. v. FARMLAND PARTNERS INC." on Justia Law

Jane Roe, a student at Southwestern Baptist Theological Seminary, reported to President Paige Patterson that she had been sexually assaulted by a fellow student, John Doe. Patterson notified the police, and Doe was expelled for violating the campus firearms policy. Later, Patterson was removed from his position by the university's board, partly due to his handling of Roe's complaint. In response, a group of donors published a letter accusing Roe of lying about the assault and claiming the encounters were consensual. Roe sued Patterson and the university for defamation, alleging that Patterson's agent provided the defamatory content for the letter.The federal district court granted summary judgment in favor of Patterson, concluding that Colter, Patterson's chief of staff, had not acted as Patterson's agent in drafting the letter. On appeal, the Fifth Circuit found that there was a fact issue regarding Colter's agency and certified two questions to the Supreme Court of Texas.The Supreme Court of Texas held that a person who supplies defamatory material to another for publication can be liable if they intend or know that the material will be published. Additionally, a defamation plaintiff can survive summary judgment without identifying specific statements made by the defendant if the evidence is legally sufficient to support a finding that the defendant was the source of the defamatory content. The court emphasized that the plaintiff must show that the defendant was the source of the defamatory statements through direct or circumstantial evidence, but need not provide verbatim evidence of the underlying communication. The case was remanded to the Fifth Circuit for further proceedings consistent with these holdings. View "ROE v. PATTERSON" on Justia Law

Houston Police Department Officers Richard Corral and C. Goodman were involved in a high-speed chase of a suspect who had solicited an undercover detective and fled in a stolen vehicle. During the pursuit, Corral's patrol car hit a curb and collided with a pickup truck driven by Ruben Rodriguez and Frederick Okon. Corral claimed the accident occurred because his brakes did not stop him in time. Rodriguez and Okon sued the City of Houston, alleging Corral's negligent driving caused their injuries.The trial court denied the City’s motion for summary judgment, which argued that Corral was protected by official immunity because he acted in good faith and that the emergency exception to the Tort Claims Act applied. The Court of Appeals for the Fourteenth District of Texas affirmed, holding that a fact issue existed regarding whether Corral knew his brakes were not functioning properly, which precluded summary judgment.The Supreme Court of Texas reviewed the case and concluded that Corral acted in good faith as a matter of law. The Court found that Corral's statement about the brakes not working did not reasonably support an inference that he had prior awareness of any defect. The Court emphasized that the summary-judgment evidence showed Corral's brakes were functional but did not stop him in time. The Court also held that the City conclusively established Corral's good faith in making the turn during the pursuit, and the plaintiffs failed to raise a fact issue to controvert this proof.The Supreme Court of Texas reversed the Court of Appeals' judgment and rendered judgment dismissing the case, holding that the City’s governmental immunity was not waived under the Tort Claims Act because Corral was protected by official immunity. View "CITY OF HOUSTON v. RODRIGUEZ" on Justia Law

A fugitive led police on a high-speed chase in Austin, during which Officer Bullock collided with Noel Powell's minivan, causing injuries. Powell, who was not at fault, sued the City of Austin for damages. The City claimed immunity under the Tort Claims Act's emergency exception, which applies if the officer was responding to an emergency and did not act with reckless disregard for safety.The trial court denied the City's plea to the jurisdiction, and the City appealed. The Court of Appeals for the Third District of Texas affirmed, finding a fact issue regarding whether Officer Bullock's actions were reckless, thus requiring further proceedings.The Supreme Court of Texas reviewed the case and held that the officer's conduct did not violate any specific law or ordinance applicable to emergency actions. The court also found that Powell did not raise a fact issue regarding the officer's recklessness. Consequently, the Tort Claims Act did not waive the City's immunity. The Supreme Court of Texas reversed the Court of Appeals' judgment and rendered judgment dismissing the case for lack of jurisdiction. View "THE CITY OF AUSTIN v. POWELL" on Justia Law

Kristen Walker gave birth to her son Henry at Baptist St. Anthony’s Hospital under the care of Dr. Rhodesia Castillo. Henry required resuscitation after birth due to asphyxiation during labor and allegedly suffered a stroke. The Walkers sued the hospital and Dr. Castillo for negligence, claiming their actions caused Henry’s permanent neurologic injury. They provided expert reports from an obstetrician, a neonatologist, and a nurse to support their claims. The defendants challenged the qualifications of the experts and the sufficiency of the reports, arguing they did not adequately explain the standards of care, breaches, and causation.The trial court overruled the defendants’ objections and denied their motion to dismiss, finding the reports provided a fair summary of the experts’ opinions as required by the Texas Medical Liability Act. The Court of Appeals for the Seventh District of Texas reversed this decision, holding that the reports contained conclusory and incomplete language that did not sufficiently explain the cause of Henry’s brain injury.The Supreme Court of Texas reviewed the case and concluded that the expert reports sufficiently explained causation and that the trial court correctly rejected the defendants’ other challenges. The court found that the reports from Drs. Tappan and Null together explained how breaches of the standard of care by Dr. Castillo and the nurses caused Henry’s injury. The court also determined that the trial court did not abuse its discretion in overruling the defendants’ objections to the experts’ qualifications. Consequently, the Supreme Court of Texas reversed the Court of Appeals’ judgment and remanded the case to the trial court for further proceedings. View "Walker v. Baptist St. Anthony's Hospital" on Justia Law

The case involves a products liability action against American Honda Motor Co., Inc. (Honda) for an alleged negligent design of a seat-belt system in a 2011 Honda Odyssey. The plaintiff, Sarah Milburn, was severely injured in a car accident while riding in an Uber vehicle, a 2011 Honda Odyssey. Milburn was seated in the third-row middle seat, which had a ceiling-mounted detachable Type 2 anchor system for the seat belt. Milburn fastened her seat belt incorrectly, leaving her lap unbelted. The accident resulted in Milburn becoming a quadriplegic.The trial court rendered judgment in favor of Milburn based on the jury's verdict, and the court of appeals affirmed. The court of appeals held that legally sufficient evidence supported the jury’s findings that the presumption of nonliability applied and that the presumption was rebutted.The Supreme Court of Texas reversed the court of appeals’ judgment. The court held that the presumption of nonliability applied as a matter of law because the 2011 Odyssey’s design complied with mandatory federal safety standards that were applicable to the Odyssey at the time of manufacture and governed the product risk that allegedly caused harm. The court further held that the presumption was not rebutted, as no evidence supports the jury’s finding that the federal safety standards failed to adequately protect the public from unreasonable risks of injury. Therefore, the court rendered a take-nothing judgment for Honda. View "AMERICAN HONDA MOTOR CO., INC. v. MILBURN" on Justia Law

Roel Canales sued Pay and Save, a grocery store, for injuries he sustained after his foot got stuck in a wooden pallet used to display watermelons, causing him to fall and fracture his elbow. Canales had visited the store hundreds of times before and had purchased watermelons without incident. The wooden pallets, which have open sides to facilitate transport by forklifts and pallet jacks, are a common and necessary tool used by grocery stores to transport and display watermelons due to their size, weight, and shape.The trial court awarded Canales over $6 million in damages. The Court of Appeals for the Fourth District of Texas found the evidence legally but not factually sufficient to support the jury's findings regarding premises liability, reversed the decision, and remanded for a new trial. The court also ruled that Canales take nothing on his gross negligence claim.The Supreme Court of Texas disagreed with the Court of Appeals. It held that the evidence was legally insufficient to support both claims because the wooden pallet was not unreasonably dangerous as a matter of law. The court noted that there was no evidence of prior complaints, reports, or injuries from similar pallets, not just at Pay and Save’s 150 stores, but also at other grocery stores. The court also found no evidence of any code, law, or regulation prohibiting or restricting the use of wooden pallets. The court concluded that the wooden pallet was a common condition, a type of hazard that people encounter and avoid every day by exercising common sense, prudence, and caution. The court reversed the Court of Appeals' judgment in part and rendered judgment for Pay and Save. View "Pay and Save, Inc. v. Canales" on Justia Law

The case revolves around a products-liability claim brought by Jennifer Parks, individually and as the guardian of Samuel Gama, against Ford Motor Company. Gama suffered serious injuries when his 2001 Ford Explorer Sport rolled over. Parks alleged that the Explorer's design made it unstable and prone to rollovers, and that the design of its roof and restraint system increased the risk of injury in a crash. Ford moved for summary judgment, arguing that Parks’ suit is foreclosed by the statute of repose in Section 16.012(b) of the Texas Civil Practice and Remedies Code, which requires that a products liability action be brought within 15 years of the sale of a product.The trial court's proceedings were protracted and winding, with the court initially granting Ford’s summary-judgment motion, then vacating that order and granting Parks’ motion for new trial, then denying Ford’s renewed summary-judgment motion, then denying Ford’s motion for reconsideration of that order, before finally granting another summary-judgment motion by Ford. The evidence that Ford sold the Explorer to a dealership more than 15 years before Parks filed suit was overwhelming.On appeal, the Court of Appeals reversed the trial court's decision, holding that Ford did not conclusively establish the 'date of the sale' from which section 16.012(b)’s claimed protection ran. The court reasoned that Ford was required to establish the specific date on which the dealership paid Ford for the Explorer in full and that Ford has not done so.The Supreme Court of Texas reversed the Court of Appeals’ judgment. The court held that the timing of a sale does not turn on the date of payment, and any inconsistency in Ford’s evidence regarding the timing of the dealership’s payment to Ford for the Explorer is immaterial and not a basis for denying or reversing summary judgment. The court concluded that Ford's evidence easily meets the test of proving that the sale must have occurred outside the statutory period, and thus, Ford is entitled to summary judgment. View "FORD MOTOR COMPANY v. PARKS" on Justia Law