Justia Texas Supreme Court Opinion Summaries

In this case arising from an inflated appraisal of certain property and governed by New York law, the Supreme Court reversed in part the court of appeals' decision affirming the jtrial court's judgment awarding Claymore Holdings $211 million in equitable relief, holding that there was no valid basis in New York law for this large award of equitable monetary relief.The subject property was a real estate project. Claymore loaned the project $250 million and took the real estate as collateral. After the borrower defaulted and the collateral's value declined, Claymore sued Credit Suisse, which helped arrange the transaction, alleging that Credit Suisse fraudulently inflated the appraisal of the real estate, inducing Claymore to make the loan, and that the faulty appraisal amounted to a breach of contract. A jury found for Claymore on the fraudulent inducement claim and awarded $40 million. The court found Credit Suisse liable for breach of contract and other theories but concluded that Claymore's damages on all claims could not be calculated with reasonable certainty. The court then awarded Claymore $211 million in equitable relief. The Supreme Court remanded the case, holding that the jury's $40 million fraud verdict must stand but that the court's award of $211 million in equitable relief must not. View "Credit Suisse AG v. Claymore Holdings, LLC" on Justia Law

In this title dispute between the State and a private landowner over portions of the submerged bed of Lone Oak Bayou the Supreme Court reversed the trial court's summary judgment in favor of the landowner, holding that there were factual disputes to be resolved, precluding summary judgment.Lone Oak Bayou was a navigable body of water located near the Gulf of Mexico. The landowner's predecessor bought land from the State that included the Bayou's bed. Later, the Legislature passed a statute (the Small Bill) validating conveyances that included the beds of "watercourses or navigable streams." The Commissioner of the General Land Office argued that the Small Bill did not validate the landowner's title to the Bayou's bed because the tide enters the Bayou and the statute conveyed only submerged beds underlying non-tidally influenced streams. The trial court granted summary judgment for the Landowner. The court of appeals affirmed. The Supreme Court reversed, holding that there were factual disputes to be resolved regarding whether the Bayou is a navigable stream within the scope of the statutory conveyance. View "Bush v. Lone Oak Club, LLC" on Justia Law

The Supreme Court reversed in part the judgment of the court of appeals affirming the trial court's judgment concluding that several general easements that Petitioner, an electric company, acquired in 1949 from the predecessors-in-title to Respondents, landowners, were fixed at a thirty-foot width and rendering judgment for Respondents, holding that the plain language of the easements did not include a fixed width for the easements, nor were the easements required to do so.Petitioner argued in this case that the easements were general easements with no fixed width. Respondents, in turn, argued that the easements should have a fixed, thirty-foot width. The trial court rendered judgment for Respondents. The court of appeals affirmed, concluding that because the original easements did not specify a width, the trial court properly admitted extrinsic evidence of past use to determine how much of Respondents' land was reasonably necessary for Petitioner to utilize pursuant to the easements. The Supreme Court reversed, holding that Respondents' properties were burdened by general easements with no defined width and that the lack of a specified width in an easement does not mandate the admission of extrinsic evidence to prescribe a width. View "Southwestern Electric Power Co. v. Lynch" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals concluding that Tex. R. Civ. P. 91a permits dismissal based on an affirmative defense and that the alleged destruction of evidence is an action "taken in connection with representing a client in litigation," thus entitling the defendant attorneys to attorney immunity.Plaintiff hired Defendants to represent her in a lawsuit. Plaintiff later sued Defendants for, inter alia, fraud, trespass to chattel, and conversion, alleging that Defendants intentionally destroyed key evidence in the case. Defendants moved to dismiss the case under Rule 91a, claiming that it was entitled to attorney immunity on all of Plaintiff's claims. The trial court granted the motion and dismissed the case. Plaintiff appealed, arguing that affirmative defenses such as attorney immunity cannot be the basis of a Rule 91a dismissal and that Defendants were not entitled to attorney immunity. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Rule 91a permits motions to dismiss based on affirmative defenses "if the allegations, taken as true, together with inferences reasonably drawn from them, do not entitle the claimant to the relief sought"; and (2) because Defendants' allegedly wrongful conduct involved the provision of legal services that conduct was protected by attorney immunity. View "Bethel v. Quilling, Selander, Lownds, Winslett & Moser, P.C." on Justia Law

In this case involving a written assignment of an overriding royalty interest in minerals produced from land in Wheeler County the Supreme Court reversed the judgment of the court of appeals reversing the trial court's judgment declaring that the assignment conveyed an overriding royalty interest in all production under the lease, holding that the assignment unambiguously conveyed the assignor's overriding royalty interest in all production under the lease.The assignment in this case identified the single well that was producing at the time of the assignment, the land on which the well was located, and the lease under which the overriding royalty interest existed. At issue was whether the assignment conveyed the assignor's interest in all production under the identified lease or only in production from the identified well or from any well drilled on the identified land. The court of appeals held that the assignment conveyed only the 3.75 percent overriding royalty interest in production from the tract of land on which the well was located. The Supreme Court reversed, holding that the assignment unambiguously conveyed all of the interest that the assignor owned at the time of the conveyance. View "Piranha Partners v. Neuhoff" on Justia Law

The Supreme Court reversed the judgment of the court of appeals ruling that, where the trial court granted a motion to dismiss without specifying the ground for its decision, the court of appeals did not have authority to order supplemental briefing but was instead required to affirm because of Appellants' failure to brief all possible grounds for the trial court's decision, holding that the court of appeals had the authority to order supplemental briefing.In this dispute over church assets, Appellees filed a motion to dismiss and a plea to the jurisdiction based on both standing and the ecclesiastical abstention doctrine. The trial court granted the motion but did not specify the grounds for its decision. Appellants appealed, but the appellate brief only addressed the standing issue. The court of appeals affirmed, holding that it lacked the authority to order supplemental briefing on the ecclesiastical abstention issue and was bound to affirm the trial court because Appellants failed to challenge all possible bases for the decision. The Supreme Court reversed, holding that because Appellants effectively raised the ecclesiastical abstention issue in their appellate briefing, the court of appeals had the authority to order additional briefing under Tex. R. App. P. 38.9. View "St. John Missionary Baptist Church v. Flakes" on Justia Law

In this property dispute between adjoining landowners the Supreme Court affirmed the decision of the court of appeals affirming the judgment of the trial court enforcing an easement, holding that a neighborhood association had standing to enforce the easement and that the evidence supported the trial court's rejection of the neighboring property owner's affirmative defenses of waiver and estoppel.Petitioner owned a parcel of undeveloped property that bordered Champee Springs Ranches neighborhood, represented here by its property owners association, and was burdened by a restrictive easement. Petitioner sought to avoid the easement to connect the property to existing public roads and to develop the parcel into a residential subdivision. To further these plans, Petitioner's predecessor built a private construction road across the easement in violation of the easement's access restriction. Champee Springs bought this lawsuit to enforce the easement. The trial court enforced the easement, and the court of appeals affirmed. The Supreme Court affirmed, holding (1) Champee Springs had standing to sue to enforce the easement; (2) the evidence supported the trial court's rejection of Petitioner's affirmative defenses; and (3) this Court declines to declare the restrictive easement void on public policy grounds. View "Teal Trading & Development, LP v. Champee Springs Ranches Property Owners Ass'n" on Justia Law

The Supreme Court reversed the judgment of the court of appeals, holding that a devise of "all...right, title and interest in and to Ranch 'Las Piedras'" referred only to a surface estate by that name, as understood by the testatrix and beneficiaries at the time the will was made, and did not include the mineral estate.Respondents asserted that their father's life estate under their grandmother's will included her interest in not only the surface of Las Piedras Ranch but also the minerals beneath it. The trial court awarded judgment in favor of Respondents. The court of appeals affirmed. The Supreme Court reversed, holding that Respondents' claims were premised on an erroneous interpretation of their grandmother's will. Therefore, Petitioners were entitled to judgment as a matter of law. View "ConocoPhillips Co. v. Ramirez" on Justia Law

The Supreme Court answered a question certified to it by the United States Court of Appeals for the Fifth Circuit regarding what constitutes good faith under the Texas Uniform Fraudulent Transfer Act (TUFTA) by holding that when a transferee on inquiry notice attempts to use TUFTA's affirmative defense that it acted in good faith to shield a transfer from the statute's clawback provision it must show, at a minimum, that it investigated its suspicions diligently.Creditors may invoke TUFTA to claw back fraudulent transfers from their debtors to third-party transferees, but if the transferee proves that it acted in good faith and the transfer was for a reasonably equivalent value, it may keep the transferred asset. The Fifth Circuit asked the Supreme Court whether a transferee on inquiry notice of fraudulent intent can achieve good faith without investigating its suspicions. The Supreme Court answered the question in the negative, holding that a transferee on inquiry notice of fraud cannot shield itself from TUFTA's clawback provision without diligently investigating its initial suspicions, regardless of whether a hypothetical investigation would reveal fraudulent conduct. View "Janvey v. GMAG, LLC" on Justia Law

The Supreme Court reversed the judgment of the court of appeals divesting the Petitioners of an interest in property they inherited from their mother, holding that the estoppel by deed doctrine did not apply in this case and that Petitioners were entitled to retain the interest.At issue was whether the estoppel by deed doctrine or the Court's opinion in Duhig v. Peavy-Moore Lumber Co., 144 S.W.2d 878 (Tex. 1940), applied to prevent Petitioners from asserting title to the interest they inherited from their mother when Petitioners' father previously purported to sell that interest to Respondents. The trial court ruled in favor of Petitioners. The court of appeals reversed and rendered judgment for Respondents based on estoppel by deed and the Court's decision in Duhig. The Supreme Court reversed, holding (1) because Petitioners claimed their interest from their mother, an independent source predating the deed at issue, neither estoppel by deed nor the decision in Duhig applied to divest Petitioners of that interest. The Court remanded the case to the trial court to determine whether damages were appropriate for Respondents' breach of warranty claim. View "Trial v. Dragon" on Justia Law