Justia Texas Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals in this negligence case arising from a motor-vehicle accident that occurred while a drilling-company employee was driving his coworkers from a drilling site to employer-provided housing after a shift, holding that the employer was not entitled to summary judgment on the injured employee’s (Plaintiff) vicarious-liability claim.Plaintiff filed suit against Employer, alleging that Employer was vicariously liable for the driver’s negligence. The trial court granted summary judgment for Employer, and the court of appeals affirmed. The Supreme Court reversed, holding that Employer was not entitled to summary judgment on either no-evidence or traditional grounds on Plaintiff’s vicarious-liability claim. View "Painter v. Amerimex Drilling I, Ltd." on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the trial court’s denial of the City of San Antonio’s plea to the jurisdiction based on governmental immunity from a suit for damages arising out of a collision between a car and a motorcycle.In her suit, Plaintiff alleged that City police officers were negligent in engaging in a high speed chase, that the City had actual notice of her claims, and that the City’s immunity was waived by the Texas Tort Claims Act (TTCA). The trial court denied the City’s plea to the jurisdiction. The court of appeals affirmed, concluding that there was a fact issue as to whether the City had actual notice of Plaintiff’s claims. The City appealed, arguing that the court of appeals applied an erroneous standard. The Supreme Court agreed and dismissed the cause for want of jurisdiction, holding that the City did not have actual notice that it was at fault in connection with the collision, as required by the TTCA for the City’s immunity to have been waived. Therefore, the trial court lacked jurisdiction over the claims. View "City of San Antonio v. Tenorio" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the trial court’s denial of the City of San Antonio’s plea to the jurisdiction based on governmental immunity from a suit for damages arising out of a collision between a car and a motorcycle.In her suit, Plaintiff alleged that City police officers were negligent in engaging in a high speed chase, that the City had actual notice of her claims, and that the City’s immunity was waived by the Texas Tort Claims Act (TTCA). The trial court denied the City’s plea to the jurisdiction. The court of appeals affirmed, concluding that there was a fact issue as to whether the City had actual notice of Plaintiff’s claims. The City appealed, arguing that the court of appeals applied an erroneous standard. The Supreme Court agreed and dismissed the cause for want of jurisdiction, holding that the City did not have actual notice that it was at fault in connection with the collision, as required by the TTCA for the City’s immunity to have been waived. Therefore, the trial court lacked jurisdiction over the claims. View "City of San Antonio v. Tenorio" on Justia Law

Except in rare circumstances, when the admissibility of a video is at issue, the proper exercise of discretion requires the trial court to actually view the video evidence before ruling on its admissibility.The trial court in this personal-injury suit arising from a workplace accident excluded video evidence without watching it. The video was taken by an investigator hired by the employer and recorded the employee engaging in physical activities over the course of two days. The employer sought to admit the surveillance video into evidence to support its defensive theory that the employee was overstating his pain and downplaying his ability to return to some form of work. Because the surveillance video was highly probative in this case, the Supreme Court reversed the judgment entered in favor of the employee awarding him nearly $10 million, holding that the video should not have been excluded under Tex. R. Evid. 403, and the trial court’s abuse of discretion was harmful. View "Diamond Offshore Services Ltd. v. Williams" on Justia Law

The limitations on mental anguish damages do not require a contractual relationship between the plaintiff and defendant before mental anguish damages can be recovered for mishandling a corpse.Cody Nelson sued SCI Texas Funeral Services, Inc. for negligence in proceeding with the cremation of his mother’s body without his authorization, claiming mental anguish damages for having been denied the opportunity to pay his last respects to his mother. The siblings of Nelson’s mother signed an authorization for SCI to arrange an expedited cremation during Nelson’s absence. The trial court rendered judgment for SCI, concluding that because SCI did not contract with Nelson, it could not be liable to him for mental anguish damages. The court of appeals reversed, concluding that SCI and Nelson had a special relationships without being in contractual privity. The Supreme Court affirmed, holding that Texas common law requires a special relationship, and not necessarily a contractual one, as the basis for mental anguish damages when the defendant had negligently mishandled a corpse. View "SCI Texas Funeral Services, Inc. v. Nelson" on Justia Law

In this slip-and-fall case, the Supreme Court reversed the judgment of the court of appeals affirming the trial court’s judgment in favor of Plaintiff and rendered a take-nothing judgment in favor of Defendant. The court held (1) Plaintiff’s claim submitted to the jury under a general-negligence theory of recovery was properly characterized as one for premises liability, and Plaintiff’s failure to request or secure findings to support his premises liability claim could not support a recovery; and (2) Defendant was under no obligation to object to Plaintiff’s submission of an improper theory of recovery, and Defendant preserved its improper theory argument by raising it in a motion for judgment notwithstanding the verdict. View "United Scaffolding, Inc. v. Levine" on Justia Law

In this slip-and-fall case, the Supreme Court reversed the judgment of the court of appeals affirming the trial court’s judgment in favor of Plaintiff and rendered a take-nothing judgment in favor of Defendant. The court held (1) Plaintiff’s claim submitted to the jury under a general-negligence theory of recovery was properly characterized as one for premises liability, and Plaintiff’s failure to request or secure findings to support his premises liability claim could not support a recovery; and (2) Defendant was under no obligation to object to Plaintiff’s submission of an improper theory of recovery, and Defendant preserved its improper theory argument by raising it in a motion for judgment notwithstanding the verdict. View "United Scaffolding, Inc. v. Levine" on Justia Law

The trial court did not abuse its discretion by denying Defendants’ motions to dismiss this health care liability action when it read several experts’ reports together to satisfy the requirement of the Texas Medical Liability Act that Plaintiffs serve each defendant with an “adequate” expert report or face dismissal of their claim. See Tex. Civ. Prac. & Rem. Code 74.351(1).Plaintiff filed health care liability claims against three defendants, alleging that their respective negligence led to her mother’s death. Plaintiff filed four separate expert reports to satisfy the Act’s requirements. Each defendant moved to dismiss Plaintiff’s claims for failure to serve adequate reports. The trial court denied the motions to dismiss. The court of appeals reversed, concluding that Plaintiff’s four reports - even when read together - did not constitute a good-faith effort to show that Plaintiff’s claims had merit. The Supreme Court reversed, holding that Plaintiff’s four expert reports provided enough information for the trial court to conclude that they constituted a good-faith effort. View "Miller v. JSC Lake Highlands Operations, LP" on Justia Law

If a plaintiff sues both public employees and their employer, section 101.106(e) of the Texas Tort Claims Act requires that the employees be immediately dismissed upon the employer’s motion, and this statutory right to dismissal accrues when the motion is filed and is not impaired by later amendments to the pleadings or motion. Respondent sued a government unit and some of its employees. The Attorney General moved to dismiss all but the tort claims against the employer, arguing that Respondent's contract claim against the employer, a state agency, was barred by sovereign immunity and that the tort claims against the employees were required to be dismissed under section 101.106(e). Thereafter, Respondent amended his petition to drop his tort claims against the employer, leaving the employees as the only tort defendants. The amended petition’s only claim against the employer was for breach of contract. The trial court dismissed Respondent's contract claim against the employer but denied dismissal of his tort claims against the employees. On appeal, the Supreme Court rendered judgment dismissing Respondent's state-law tort claims against the employees, holding that, following Respondent's amended petition, Defendants remained entitled to dismissal of the tort claims asserted against the employees in Respondent's original petition, as requested in Defendants’ original motion to dismiss. View "University of Texas Health Science Center at Houston v. Rios" on Justia Law

In this tort suit arising from a real estate transaction, the Supreme Court conditionally granted mandamus relief to Relators from an order denying leave to designate Plaintiffs’ legal advisors as responsible third parties.Relators’ motion to designate was filed long after an initial trial date but seventy-six days before a new trial setting. The trial court denied the motion to designate without granting leave to replead. The court of appeals denied mandamus relief. The Supreme Court conditionally granted Relators’ petition for writ of mandamus, holding that the trial court erred in denying Relators’ motion because it was filed more than sixty days before the trial setting and the court did not afford Relators an opportunity to cure any pleading deficiency. View "In re Coppola" on Justia Law