Justia Texas Supreme Court Opinion Summaries

The Supreme Court reversed in part the judgment of the court of appeals reversing in part the trial court's grant of summary judgment for Defendant in this negligence and premises-liability case arising from a fatal construction-site accident, holding that remand was required in light of recent opinion.Plaintiffs sued Defendant for negligence, gross negligence, and premises liability. The trial court granted summary judgment for Defendant. The court of appeals reversed as to the negligence and premises-liability claims. The Supreme Court remanded the case, holding that, in applying the general rule and holding that Plaintiffs' petition could not constitute competent summary-judgment evidence, the court of appeals did not have the benefit of this Court's recent opinions in Regency Field Services, LLC v. Swift Energy Operating, LLC, 622 S.W.3d 807 (Tex. 2021) and Energen Resources Corp. v. Wallace, 642 S.W.3d 502 (Tex. 2022). The Supreme Court remanded this case for further consideration of the instant case in light of Regency and Energen and other subsequently issued opinions providing guidance on the legal issues presented. View "Weekley Homes, LLC v. Paniagua" on Justia Law

The Supreme Court conditionally granted mandamus relief in this challenge to certain discovery rulings in the underlying vehicle-collision lawsuit, holding that the challenged rulings contravened this Court's precedents regarding discovery requests that are overbroad as a matter of law.After the Supreme Court requested a response to the mandamus petition the real parties interest withdrew the challenged discovery requests, thus, they argued, rendering Petitioner's petition moot and depriving the Supreme Court of jurisdiction. The Supreme Court conditionally granted relief, holding that the discovery ordered was overbroad and that the trial court abused its discretion. View "In re Contract Freighters, Inc." on Justia Law

The Supreme Court conditionally granted UPS Ground Freight, Inc.'s petition for writ of mandamus and directed the trial court to vacate a portion of a September 30, 2020 discovery order in this wrongful-death suit, holding that the discovery requests were overbroad and that UPS had no adequate remedy by appeal.In the discovery order at issue, the trial court ordered UPS to product the results of alcohol and drug tests conducted on all current and former drivers at its Irving facility for certain periods preceding a fatal multi-vehicle accident. The Supreme Court agreed with UPS that the discovery requested and compelled by the trial court was insufficiently narrowed and was overly broad in scope. The Court ordered the trial court to vacate the portion of the discovery order compelling production of information and records pertaining to drug-and-alcohol test results for current and former UPS driver who were not parties to the litigation and who were not involved in the accident giving rise to this action. View "In UPS Ground Freight, Inc." on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the trial court's judgment declaring invalid the Department of Family and Protective Services Rule 748.7, which governs immigration detention centers, and enjoining the Department from granting licenses under the rule, holding that Plaintiffs had standing to challenge Rule 748.7.Plaintiffs, a nonprofit advocacy group, a day-care operator and several detainee mothers, individually and on behalf of their children, brought this action alleging that the Department lacked authority to adopt Rule 748.7 because it increased the safety risk to the detainees and their children. The trial court declared the rule invalid and enjoined the Department from granting licenses under the rule. The court of appeals reversed, holding that Plaintiffs lacked standing to assert their claims. View "Grassroots Leadership, Inc. v. Texas Department of Family & Protective Services" on Justia Law

The Supreme Court reversed the judgment of the court of appeals dismissing Petitioner's appeal for lack of jurisdiction, holding that Petitioner's filing error did not deprive the court of appeals of subject matter jurisdiction.Petitioner brought multiple wrongful death and survival claims against several defendants. The trial court granted Respondents' motion for a take-nothing judgment. An ensuing severance transformed the interlocutory summary judgment into a final and appealable judgment, commencing the thirty-day period to file a notice of appeal. Petitioner then moved for a new trial. At issue was whether Petitioner's ensuing notice of appeal was timely, which depended on whether Petitioner's motion for new trial was effective. The court of appeals held that the motion for new trial was ineffective because Petitioner filed it under the wrong case number and dismissed the appeal for lack of jurisdiction. The Supreme Court reversed, holding (1) Petitioner's motion for new trial effectively extended the trial court's plenary power and, correspondingly, the appellate timelines; and (2) therefore, the appeal was timely. View "Mitschke v. Borromeo" on Justia Law

The Supreme Court reversed the judgment of the trial court affirming a verdict for the family of a teenager who committed suicide after seeking treatment for depression from her pediatric healthcare providers, holding that the testimony did not establish the necessary but-for causation required by precedent.The expert testimony at trial established negligence on the part of the teen's medical providers but did not establish that, but for the negligence, the teen would not have committed suicide. Plaintiffs sued their daughter's providers for negligence and gross negligence. The jury found that certain providers were liable, and the trial court awarded $1.285 million to Plaintiffs. The court of appeals affirmed. The Supreme Court reversed, holding that there was no evidence that the providers' care proximately caused the teen's suicide. View "Pediatrics Cool Care v. Thompson" on Justia Law

The Supreme Court denied a petition for writ of mandamus sought by Relators for relief from trial court orders granting Christina Broussard's motions to quash certain discovery subpoenas in this case brought by Broussard against Relators for personal injuries and economic losses following a rear-end collision, holding that the discovery requests sought relevant information.The subpoenas sought post-accident medical-billing information from Broussard's medical providers and third-party production of Broussard's pre-accident medical, education, employment, and insurance records. Relators argued that the requested discovery was relevant to the issue of damages causally attributable to the accident. The trial court quashed the discovery subpoenas. The Supreme Court denied mandamus relief without prejudice to Relators' seeking relief, if necessary, after the trial court has had an opportunity to reconsider its rulings, holding that the trial court should reconsider its orders in light of this Court's opinion in In re K&L Auto Crushers, LLC, 627 S.W.3d 239 (Tex. 2021). View "In re Central Oregon Truck Co., Inc." on Justia Law

The Supreme Court held that a party who does not receive notice of an interlocutory order denying arbitration under the Federal Arbitration Act in time to appeal because of the trial court clerk's error may seek review by mandamus.Plaintiff sued her employer alleging negligence. Defendant moved to compel arbitration based on its mandatory arbitration policy. The trial court denied the motion to compel, ruling that the policy was unconscionable. The court of appeals remanded the case, after which Defendant filed a supplemental motion to compel arbitration. The trial court denied the motion, but the clerk failed to give Defendant notice of the order. Defendant finally received notice of the order five months after it issued. The Supreme Court issued a writ of mandamus and directed the trial court promptly to issue an order compelling arbitration of Plaintiff's claims, holding (1) the clerk's failure to give notice of the trial court's order deprived Defendant of an adequate appellate remedy; and (2) the arbitration agreement was not illusory. View "In re Whataburger Restaurants LLC" on Justia Law

In this case involving a claim for wrongful imprisonment compensation under the Tim Cole Act, Tex. Civ. Proc. & Rem. Code 103.001-.154, the Supreme Court denied G.S.'s request for mandamus relief, holding that G.S. did not satisfy the Act's requirements.G.S. pleaded guilty to indecency with a child but was later granted habeas relief based on ineffective assistance of counsel. After it was discovered that G.S.'s alleged victim had fabricated the accusations and G.S. arrest and conviction were expunged, G.S. applied for wrongful imprisonment compensation under the Act. The Texas Comptroller of Public Accounts denied the application. G.S. subsequently filed his petition for writ of mandamus. The Supreme Court denied the writ, holding that G.S. did not establish his actual innocence as required by the Act, and therefore, he failed to prove his entitled to compensation under the Act. View "In re G.S." on Justia Law

In this wrongful death and survival action brought against an automobile insurer, the Supreme Court reversed the judgment of the court of appeals reversing the trial court's judgment in favor of the insurer as to Plaintiff's negligence and gross negligence claims, holding that the court of appeals erred.An insured motorist was involved in a single car accident. The motorist's husband later arrived and began taking photos, but while he was engaged in that activity on the side of the road, he was struck by another vehicle and killed. Plaintiff, the motorist, brought this action alleging that the insurer had instructed her to take the photos and that her husband was complying with that instruction when the other driver hit him. Thus, Plaintiff argued, the insurer proximately caused her husband's death. The trial court granted summary judgment for the insurer on the negligence and gross negligence claims. The court of appeals reversed. The Supreme Court reversed, holding that Defendant did not have a duty to exercise reasonable care in providing post-accident guidance so as not to increase the risk of harm to its insured. View "Elephant Insurance Co., LLC v. Kenyon" on Justia Law