Justia Texas Supreme Court Opinion Summaries

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

The Supreme Court reversed the judgment of the court of appeals affirming the trial court's judgment for Plaintiff, a cardiovascular surgeon who sued Defendant, a hospital and Plaintiff's former employer, for engaging in a retaliatory "whisper campaign" against him, holding that the lower courts erred.After leaving the employment of Defendant for a new rival, Plaintiff brought this complaint alleging that Defendant used faulty data on his patients' mortality rates to suppress competition and injure his reputation and practice. The jury rejected Plaintiff's anticompetition claims but concluded that the hospital had defamed him and disparaged his professional association. The trial court granted summary judgment for Plaintiff, and the court of appeals affirmed. At issue on appeal was how a reasonable juror would interpret the charge that was given for the defamation and business disparagement claims. The Supreme Court held (1) the plain text of the charge must be given its commonsense meaning in the context of the case; and (2) the trial court erred in awarding Plaintiff damages for defamation and business disparagement. View "Memorial Hermann Health System v. Gomez" on Justia Law

The Supreme Court reversed the judgment of the court of appeals as to attorney's fees in this case concerning whether Defendant, a condominium association, was entitled to attorney's fees after obtaining a take-nothing judgment on claims by Plaintiff, a unit owner, the Supreme Court held that the fee award was authorized by Tex. Prop. Code 82.161(b).Plaintiff sued Defendant for, among other things, fraud, civil conspiracy, breach of contract, and negligence. Defendant filed a counterclaim for declaratory judgment and requested attorney's fees. The trial court granted Defendant's motion on twelve declaratory issues. After a trial, the court granted judgment for Defendant and awarded attorney's fees. The court of appeals affirmed the judgment for Defendant but reversed the award of attorney's fees. The Supreme Court reversed in part, holding that Defendant was a prevailing party under Tex. Prop. Code 82.161(b) and was thus entitled to reasonable attorney's fees. View "Sunchase IV Homeowners Ass'n v. Atkinson" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the trial court's grant of summary judgment in this case brought under Chapter 95 of the Civil Practice and Remedies Code, holding that because the landowner conclusively established that Plaintiff was adequately warned of the dangerous condition, the trial court properly granted summary judgment.Plaintiff was working as a power lineman for OTI Energy Services when he was injured while working to de-energize part of an energized power line and transformer. Plaintiff sued SandRidge Energy, which hired OTI, for negligence, alleging that SandRidge could not establish a defense under Chapter 95 because it exercised control over the manner in which he performed the work, knew of the dangerous condition, and failed adequately to warn him of that condition. The trial court granted summary judgment for SandRidge. The court of appeals reversed, holding that Plaintiff had raised a fact issue as to whether SandRidge failed to provide an adequate warning. The Supreme Court reversed, holding (1) the evidence conclusively established that Plaintiff was fully aware of the dangerous condition that caused his injury; and (2) therefore, the trial court properly granted summary judgment. View "SandRidge Energy, Inc. v. Barfield" on Justia Law

The Supreme Court held that the Texas Workers' Compensation Act (TWCA) does not affect the enforceability of an additional-insured provision under the Texas Anti-Indemnity Act (TAIA).A general contractor's employee injured in an accident obtained a negligence judgment in Texas state court against the subcontractor that operated the crane (Berkel) and the company that leased the crane (Maxim). Berkel was an indemnity and Maxim was an indemnity for TAIA purposes because Berkel had provided Maxim with coverage as an additional insured. After the injured worker settled with Maxim, Maxim unsuccessfully sought reimbursement from Berkel's insurer (Zurich). The court of appeals reversed the judgment against Berkel, concluding that Berkel and the injured worker were "statutory co-employees" of the general contractor under the TWCA, and therefore, the TWCA provided the worker's exclusive remedy. In a separate suit in federal court, Maxim and Zurich disputed over whether the additional-insured coverage was enforceable. The Supreme Court answered a certified question by holding that the word "employee" in Tex. Ins. Code 151.103 bears its common meaning, which is not affected by whether the indemnity and injured employee are considered co-employees for purposes of the TWCA. View "Maxim Crane Works, LP v. Zurich American Insurance Co." on Justia Law