Justia Texas Supreme Court Opinion Summaries

Jose Medellin, an experienced independent contractor, was hired to assist with a roofing project at an apartment complex in San Antonio. While working on the roof, Medellin, along with other workers, was responsible for stretching a rubber membrane across the roof’s surface. During this task, Medellin lost track of the roof’s edge, fell approximately thirty feet, and suffered serious injuries. He subsequently sued the general contractor, alleging both negligent activity and premises liability, arguing that the lack of adequate safety measures contributed to his fall.The case proceeded to a jury trial in a Texas district court, where the jury found JMI Contractors, LLC liable under both negligent activity and premises liability theories, awarding Medellin over $3.3 million in compensatory damages and an additional $1 million in exemplary damages. JMI appealed to the Court of Appeals for the Fourth District of Texas, which initially ordered a new trial on unrelated grounds. Upon rehearing, the court of appeals affirmed the trial court’s judgment, holding that the necessary-use exception applied to Medellin’s premises liability claim, and that JMI owed him a duty of care due to its control over jobsite safety.The Supreme Court of Texas granted JMI’s petition for review. The Supreme Court held that Medellin’s claim properly sounded in premises liability, not negligent activity, as his injury arose from a dangerous condition (an unguarded roof edge) rather than contemporaneous conduct by JMI. Crucially, the Court held that independent contractors cannot recover under premises liability for injuries caused by open and obvious dangers and that the necessary-use exception does not apply to them. Accordingly, the Supreme Court of Texas reversed the judgment of the court of appeals and rendered a take-nothing judgment in favor of JMI. View "JMI CONTRACTORS, LLC v. MEDELLIN" on Justia Law

The dispute involved neighboring commercial properties in Fort Worth, Texas. After a store was constructed on one property, the adjacent property began to experience flooding during rainfall, which led to silt and trash accumulation and eventually damaged the building and parking lot. The owner of the flooded property documented the issue over several years and sought remedies from the city, but received no resolution. Engineering reports concluded that the store’s drainage system caused increased groundwater and stormwater runoff onto the neighbor’s land.The owner of the flooded property sued the store owner and related parties for nuisance, trespass, negligent and intentional diversion of water, and violations of the Texas Water Code, seeking damages and permanent injunctive relief. Two groups of defendants moved for summary judgment, arguing that all claims were barred by the two-year statute of limitations. The District Court for Tarrant County granted both motions for summary judgment in separate orders, one of which explicitly stated it was final and disposed of all parties and claims. The trial court subsequently issued a clarifying order allowing for a permissive interlocutory appeal but did not clarify whether the summary judgment orders’ finality was undone.The Court of Appeals for the Second District of Texas determined that the trial court’s summary judgment was final and accepted appellate jurisdiction. It held that while the two-year statute of limitations barred claims for damages, it did not bar injunctive relief to abate a nuisance. Upon review, the Supreme Court of Texas held that appellate jurisdiction was proper because the summary judgment order was expressly final and was not undone by the subsequent clarifying order. On the merits, the Supreme Court determined that injunctive relief cannot be granted without an underlying cause of action, and that the two-year statute of limitations applies to all claims for damages and injunctions in this case. The judgment of the court of appeals was reversed, and the trial court’s judgment was reinstated. View "FAMILY DOLLAR STORES OF TEXAS, LLC v. JLMH INVESTMENTS, LLC" on Justia Law

The case concerns landowners whose property in Harris County, Texas, was condemned by the State for a highway project. After initially offering compensation, the State initiated condemnation proceedings, and the parties settled on a value for the property. Years later, the planned highway route was altered, leaving a portion of the condemned land unused. When the State indicated that some of the property was now considered surplus but refused to sell it back, the landowners assigned their rights to JRJ Pusok Holdings, LLC, to pursue a statutory right of repurchase under Texas law.JRJ filed suit in a Harris County civil court at law against the State of Texas and the Director of Right of Way, asserting a statutory right to repurchase the surplus property. The State responded with a plea to the jurisdiction, asserting sovereign immunity and lack of justiciability. The trial court granted the State’s plea and dismissed the case. The Court of Appeals for the Fourteenth District of Texas reversed the dismissal as to the repurchase claim, holding that the State’s sovereign immunity was waived for such claims, that the property had been acquired “through eminent domain,” and that the county court at law had jurisdiction.The Supreme Court of Texas affirmed the Court of Appeals’ decision. It held that the State is not immune from statutory repurchase claims arising under Chapter 21 of the Texas Property Code when condemned property is no longer necessary for public use. The court clarified that property acquired through a condemnation suit, even if settled before judgment, is acquired “through eminent domain.” It also held that a landowner may repurchase only the portion of property no longer necessary for public use and that county courts at law have concurrent jurisdiction over these claims. The court remanded the case for further proceedings. View "THE STATE OF TEXAS v. JRJ PUSOK HOLDINGS, LLC" on Justia Law

A borrower obtained a home equity line of credit from a lender, secured by his Texas homestead. The promotional loan terms offered a reduced interest rate provided certain conditions were met, but one such condition—maintaining a $25,000 loan balance within fifteen days of closing—did not apply to Texas homestead loans under the state constitution. After several years, the borrower realized the lender had charged him a higher interest rate than agreed, resulting in an overcharge of approximately $10,000. The lender initially disputed the error but later acknowledged it and offered to pay the overcharged amount plus interest. The borrower, however, sought a much larger remedy: forfeiture of the entire outstanding loan based on the Texas Constitution’s home equity loan provisions.The case was first heard in the 68th District Court of Dallas County, which granted summary judgment for the lender, ruling that the borrower was entitled to actual damages only, not forfeiture of the loan principal and interest. The lender paid the borrower his actual damages. On appeal, the Court of Appeals for the Fifth District of Texas affirmed the trial court’s judgment, holding that the forfeiture remedy described in Article XVI, Section 50(a)(6)(Q)(x) of the Texas Constitution is limited to breaches of constitutionally mandated terms and conditions, not any and all breaches of a loan agreement.The Supreme Court of Texas reviewed the case. It held that the constitutional forfeiture remedy applies only to breaches of the terms and conditions specifically enumerated in the Texas Constitution’s home equity loan provisions, not to ordinary contract breaches or errors outside those constitutional requirements. The Court affirmed the judgment of the court of appeals, concluding that the borrower was not entitled to forfeiture because the lender’s error did not violate a constitutional obligation. View "STAUB v. BBVA USA" on Justia Law

Emily Lehmberg sued Studio E. Architecture and Interiors, Inc. and other parties over the remodeling of her home. Studio E. moved to dismiss the claims against it, arguing that Lehmberg failed to file a certificate of merit as required by Texas Civil Practice and Remedies Code Section 150.002, which mandates such a certificate for claims against certain professionals. Lehmberg contended that her claims were not based on professional services but rather on alleged dishonesty and fraud. She also argued that Studio E. had waived its right to seek dismissal by waiting more than two years to file its motion. While the case against other defendants remained pending, the trial court denied Studio E.’s motion, and Studio E. filed an interlocutory appeal.The Court of Appeals for the Fourth District of Texas reversed the trial court’s decision, holding that Section 150.002 applied, and that Studio E. had not waived its right to seek dismissal. The appellate court remanded the case to the trial court to determine whether dismissal should be with or without prejudice. The trial court dismissed the original claims against Studio E. without prejudice, but allowed Lehmberg to file an amended petition with a certificate of merit, reasserting her claims. Studio E. moved to dismiss the amended petition, arguing that reassertion was not permitted in the same lawsuit, but the trial court denied the motion. Studio E. appealed again, and the court of appeals affirmed, holding that amending the petition was proper.The Supreme Court of Texas reviewed the case and held that when claims against a defendant are dismissed without prejudice under Section 150.002, and the underlying lawsuit remains pending, the plaintiff may reassert those claims in an amended petition along with a certificate of merit. The Court affirmed the judgment of the court of appeals. View "STUDIO E. ARCHITECTURE AND INTERIORS, INC. v. LEHMBERG" on Justia Law

A woman was killed when a construction crane collapsed during a storm, striking her apartment building. Her parents, acting individually and on behalf of her estate, brought a negligence and gross negligence lawsuit against several defendants, primarily three related construction and development entities. Following a jury trial, the jury found these entities had engaged in a joint enterprise that caused the woman’s death and awarded over $360 million in compensatory damages, along with $500 million in exemplary damages (which the trial court later reduced under statutory caps). The court entered judgment holding the entities jointly and severally liable for the compensatory damages, with two entities also severally liable for exemplary damages.The defendants, collectively known as the Greystar Entities, filed a single $25 million joint supersedeas bond to suspend execution of the judgment during their appeal. The plaintiffs challenged the sufficiency of this joint bond in the 191st Judicial District Court, Dallas County, arguing that Texas law capped the required bond at $25 million per debtor, not per judgment. The trial court agreed, ruling that each entity needed to post its own $25 million bond and that the joint bond could suspend execution for only one entity unless the defendants designated which one. The Greystar Entities appealed to the Fifth Court of Appeals at Dallas, which affirmed the trial court’s order.The Supreme Court of Texas reviewed the case on a petition for writ of mandamus. The Court held that, under Texas Civil Practice and Remedies Code Section 52.006(b), the $25 million cap on supersedeas bonds applies per judgment debtor, not collectively to all debtors in a single judgment. The Court also held that the trial court abused its discretion by immediately invalidating the joint bond without allowing a reasonable time for compliance. The Supreme Court conditionally granted partial mandamus relief, directing the trial court to provide additional time for each entity to post an individual bond. View "IN RE GREYSTAR DEVELOPMENT & CONSTRUCTION, L.P." on Justia Law

A purchaser acquired a large ranch in Texas that was crossed by a decades-old electric distribution line operated by an electric cooperative. The cooperative had constructed the original line in 1947, relying on an unrecorded document from a prior owner’s estate purporting to grant an easement, though this document was never filed in county records. The line was visible and marked in a survey at the time of the purchaser’s acquisition. In 2012, the cooperative undertook a significant upgrade of the line to serve a new customer and substation, tripling the number of poles and nearly doubling the number of wires, without recorded evidence of a valid easement for the expanded use. The purchaser objected, asserting trespass after learning of the upgrade.The trial in the 63rd District Court of Kinney County resulted in a jury finding that the cooperative had not established a written or prescriptive easement, but did hold an easement by estoppel, based on reliance upon the prior owner’s unrecorded document. The jury further found that the upgrade did not exceed the scope of this easement, and the trial court rendered judgment for the cooperative. The Fourth Court of Appeals in San Antonio affirmed, holding that evidence supported both the existence and scope of the easement by estoppel.Upon review, the Supreme Court of Texas concluded that legally sufficient evidence supported the jury’s finding that an easement by estoppel existed because the cooperative had detrimentally relied on the prior owner’s representation and the purchaser had actual notice of the line. However, the Court held as a matter of law that the scope of the easement by estoppel was limited to the cooperative’s original use, and that the substantial upgrade—serving new customers and requiring significantly more infrastructure—exceeded that scope. The Supreme Court of Texas reversed the judgment of the court of appeals, rendered judgment for the purchaser on the trespass claim, and remanded the case for further proceedings. View "BOERSCHIG v. RIO GRANDE ELECTRIC COOPERATIVE, INC." on Justia Law

Two neighboring landowners in Victoria County, Texas, became embroiled in a dispute after one party, the Kuceras, constructed a dam and berms while developing their property, allegedly altering a creek’s natural flow and causing flooding on the Kolles’ adjacent land. The Kolles, who jointly own and use their property for cattle grazing, sued the Kuceras for violating the Texas Water Code and on several common-law grounds, including nuisance and trespass. The Kuceras attempted to designate Victoria County as a responsible third party, arguing the county’s actions might have contributed to the flooding, but the trial court struck this designation due to lack of evidence that the county violated any legal standard. At trial, a jury found the Kuceras liable under multiple theories, apportioned responsibility among them, and awarded the Kolles both economic and exemplary damages.On appeal, the Thirteenth Court of Appeals concluded that the Kolles could not recover damages for loss of use because the injury to their property was permanent, reducing the total economic damages from $425,000 to $175,000. However, the court affirmed the remainder of the trial court’s judgment, including the exemplary damages.The Supreme Court of Texas reviewed whether the exemplary damages awarded exceeded statutory limits under Civil Practice and Remedies Code Chapter 41. The Court held that the statutory cap on exemplary damages must be calculated based on the percentage of economic damages attributable to each defendant, not the total damages awarded. Further, when economic damages are awarded jointly to plaintiffs as a single sum, the cap applies to each defendant based on that single amount. The Court reversed the court of appeals in part and remanded the case to the trial court to reallocate the exemplary damages and consider whether, in light of reduced actual damages, the exemplary awards are unconstitutionally excessive. View "K & K INEZ PROPERTIES, LLC v. KOLLE" on Justia Law

An Oklahoma company, formed to acquire mineral rights in Appalachia, alleged that two Texas parties failed to convey certain West Virginia mineral interests as contractually agreed. The Oklahoma company, which included non-Texas owners and participants, had funded the purchase of these rights, but a number of mineral deeds were recorded in the name of the Texas seller rather than the buyer. As a result, royalties from those mineral rights were paid to the seller. The Oklahoma plaintiff sought to compel the Texas defendants to reform the deeds, perform their contractual obligations, declare the plaintiff’s entitlement to the royalties, and enjoin the defendants from transferring the disputed interests.The 141st District Court in Tarrant County, Texas, denied the defendants’ plea to the jurisdiction and ultimately granted summary judgment for the plaintiff, awarding specific performance, deed reformation, declaratory relief, an injunction, and monetary relief. The court found it had jurisdiction over the parties and the contract, even though the mineral rights were located in West Virginia. On appeal, the Court of Appeals for the Second District of Texas reversed, holding that Texas courts lacked subject-matter jurisdiction because the suit’s gravamen was the adjudication of title to foreign (West Virginia) real property.The Supreme Court of Texas reviewed the matter and disagreed with the appellate court’s application of the so-called “gist” rule. The Supreme Court held that Texas courts with personal jurisdiction over the parties may issue in personam judgments concerning contractual obligations to convey out-of-state real property, as long as the judgment binds only the parties and does not purport to establish or alter title to the property by the court’s own force. The Supreme Court reversed the appellate court’s judgment and remanded for consideration of remaining issues. View "BRAXTON MINERALS III, LLC v. BAUER" on Justia Law

The case involves Nadine Realme, who participated in a Thanksgiving “turkey trot” fun run organized by the City of San Antonio. While following the course through a public park, Realme tripped over a metal pole fragment and broke her arm. She sued the City, alleging negligent maintenance of the park. The City asserted that Texas’s Recreational Use Statute barred ordinary negligence liability for injuries occurring during recreational activities on government property, arguing that the turkey trot was a “recreational” activity under the statute.In the 216th District Court, Realme prevailed. The Fourth Court of Appeals affirmed, reasoning that while an organized footrace is “recreation” in common parlance, the statute required activities to be “associated with enjoying nature or the outdoors.” The appellate court concluded that the turkey trot, as an organized human event focused on completing the race, was not sufficiently connected to enjoyment of nature to qualify as “recreation” under the statute. It further determined that Realme’s purpose—to have fun and capture a social media picture—did not establish she entered the premises to enjoy nature or the outdoors.The Supreme Court of Texas reviewed the statutory definition of “recreation,” emphasizing its nonexhaustive list and ordinary meaning. It held that a community fun run is “recreation” because it provides diversion, play, and enjoyment, fitting the statute’s scope. The Court ruled that the Recreational Use Statute immunizes the City from ordinary negligence liability, reversing the Fourth Court of Appeals’ judgment and rendering judgment for the City on that claim. The Court remanded the case to the Fourth Court of Appeals to address Realme’s gross negligence claim, which had not been considered previously. View "CITY OF SAN ANTONIO v. REALME" on Justia Law