Justia Texas Supreme Court Opinion Summaries

Respondents were successors-in-interest to 380 acres of land once owned by Baker, now deceased. Petitioners entered into a lease agreement with Baker that contained an option allowing Petitioners to buy the land if Baker decided to sell it. Petitioners and Baker subsequently agreed that Petitioners would purchase the 380 acres for $470,000. Petitioners attempted to exercise their right to buy the property under the agreement, but Respondents brought a declaratory judgment action to void the agreement. The trial court rendered a final judgment for Petitioners. The court of appeals reversed, concluding (1) the agreement was ambiguous as to whether it was a presently binding contract or merely an agreement to agree, and (2) therefore, the agreement's enforceability was a fact issue that should not have been determined by summary judgment. The Supreme Court reversed, holding that the agreement contained all material terms and was an enforceable contract as a matter of law. Remanded. View "McCalla v. Baker's Campground, Inc." on Justia Law

Homes built with an exterior insulation and finish system (EIFS) suffer serious water damage that worsens over time. Homebuilder began a remediation program in which it offered to homeowners to remove exterior EIFS from the homes it had built and to replace it with conventional stucco. Almost all the homeowners accepted Homebuilder's offer of remediation. Homebuilder sought indemnification for the costs from its insurers (Insurers). Insurers denied coverage, preferring instead to wait until the homeowners sued. This litigation ensued. Now, only one insurer remained. The court of appeals reversed the trial court's judgment in favor of Homebuilder, finding (1) Homebuilder failed to establish its legal liability to the homeowners to trigger Insurer's coverage; and (2) Homebuilder failed to offer evidence of damages covered by the policy. The Supreme Court reversed, holding (1) Homebuilder's settlements with the homeowners established both Insurer's legal liability for the property damages and the basis for determining the amount of loss; and (2) Insurer's policy covered Homebuilder's entire remediation costs for damaged homes. View "Lennar Corp. v. Markel Am. Ins. Co." on Justia Law

Plaintiff owed the surface estate of a forty-acre tract. Defendant, the lessee of the tract's severed mineral estate, constructed a well site on Plaintiff's tract without Plaintiff's approval. Plaintiff filed suit seeking an injunction requiring Defendant to remove the well, asserting that Defendant failed to accommodate his existing use of the surface so Defendant's acts exceeded its rights in the mineral estate and constituted a trespass. The trial court granted summary judgment for Defendant, and the court of appeals affirmed. The Supreme Court affirmed, holding that, even assuming that the failure of Defendant's operations to accommodate Defendant's existing use would have been sufficient to support injunctive relief, Plaintiff failed to raise a material fact issue as to whether Defendant failed to accommodate his use. View "Merriman v. XTO Energy, Inc." on Justia Law

This case involved an inverse-condemnation dispute over ten acres. At issue was who had title to the parcel: the Texas Department of Transportation (TxDOT), the City of Edinburg (City), or API Pipe Supply and Paisano Service Company (collectively, API). In 2003, the trial court awarded the City a "fee title" to the property subject to a drainage easement granted to TxDOT. In 2004, the trial court entered a judgment purporting to render the 2003 judgment null and void. API claimed the judgment gave API fee-simple ownership, subject to a drainage easement granted to the City, and, via subsequent conveyance, to TxDOT. In 2005, TxDOT began its drainage project. API, relying on the 2004 judgment, brought a takings claim for the value of the removed soil. The trial court held in favor of API, and the court of appeals affirmed. The Supreme Court reversed and dismissed the suit, holding (1) the 2004 judgment was void and therefore could not supersede the valid 2003 judgment; (2) API was statutorily ineligible for "innocent purchaser" status, and equitable estoppel was inapplicable against the government in this case; and (3) because API held no interest in the land, API's takings claim failed. View "Dep't of Transp. v. A.P.I. Pipe & Supply, LLC" on Justia Law

El Dorado Land Company sold property to the City of McKinney for use as a park. El Dorado's special warranty deed provided that the conveyance was subject to the restriction that the community only be used for that purpose. If the City decided not to use the property as a community park, the deed granted El Dorado the right to purchase the property. Ten years after acquiring the property, the City built a public library on part of the land. El Dorado notified the City it intended to exercise its option to purchase, but after the City failed to acknowledge El Dorado's rights under the deed, El Dorado sued for inverse condemnation. The trial court sustained the City's plea to the jurisdiction, finding that El Dorado's claim did not involve a compensable taking of property but, rather, a breach of contract for which the City's governmental immunity had not been waived. The court of appeals affirmed. The Supreme Court reversed, holding that, in its deed to the City, El Dorado retained a reversionary interest in the property that was a property interest capable of being taken by condemnation. Remanded. View "El Dorado Land Co., LP v. City of McKinney" on Justia Law

Landowner purchased property for the purpose of developing the land, obtained permits, and filled a portion of the property to the 100-year flood level. The municipality subsequently constructed a facility partly on the property that would detain storm water on the property in a significant flood, thus causing the property again to be below the 100-year flood level and undevelopable without additional fill. Landowner sought damages under statutory and inverse condemnation theories. The trial court ruled in favor of Landowner and awarded damages of $694,600. The court of appeals reversed as to the inverse condemnation claim, holding the claim was premature because the property had not yet flooded. The Supreme Court reversed, holding that the claim was not premature because Landowner's claim was for the present inability to develop the property as previously approved unless the property was filled. Remanded. View "Kopplow Dev., Inc. v. City of San Antonio" on Justia Law

A small group of landowners sought to certify a class composed of all owners of any real property interests in a twelve-mile stretch of land located adjacent to the Canadian River to litigate alleged takings claims against the State. The trial court denied certification, finding that the landowners failed to satisfy two prerequisites required by Tex. R. Civ. P. 42(a) and any one of the three Rule 42(b) requirements. The court of appeals affirmed, concluding that certain conflicts identified by the trial court prevented the landowners from satisfying Rule 42(a)(4)'s adequacy-of-representation prerequisite. The Supreme Court reversed, holding (1) the trial court abused its discretion by relying on the conflicts identified in its order denying class certification to establish that the landowners failed to satisfy Rule 42(a)(4)'s adequacy-of-representation prerequisite; and (2) the court of appeals erred when it affirmed the trial court's order on the same grounds. View "Riemer v. State" on Justia Law

This appeal questioned the validity of certain conditions a grantor placed on a dedicated public-street easement. The easement in question provided for a 100-foot-wide public right of way, but the instrument dedicating the land also provided that the street's curb lines were to be fifteen feet inside the street's boundary lines. The issue was whether this curb-line condition limited the dedication such that only the seventy-foot area between the curb lines could be used for vehicular traffic. The court of appeals concluded that the curb-line condition effectively limited the public easement in this way. The court further suggested that the State would have to use its eminent domain powers if the public roadway needed to be improved or widened beyond the existing curb lines. The Supreme Court reversed and remanded, holding (1) the State need not condemn property already already dedicated for a public street before widening the existing roadway; and (2) therefore, the State had the right to improve the existing roadway to the boundary of the dedicated street line notwithstanding the curb-line condition. View "State v. NICO-WF1, LLC" on Justia Law

A school district (District) obtained an in rem delinquent property tax judgment against an oil and gas lease that Respondent owned and operated. Respondent did not appeal, and the District foreclosed its judgment lien on the leasehold, taking ownership. The Railroad Commission ordered Respondent to plug a well on the lease. Respondent did not comply, and the Commission plugged the well and brought an enforcement action in court to recover the costs of the operation and the penalty. Respondent and the Commission settled. Respondent then sued the District, alleging in part that the District's actions had resulted in a taking of his property requiring compensation. The trial court dismissed Respondent's action for want of jurisdiction, but the court of appeals reversed and remanded with respect to the takings claim. The Supreme Court reversed and dismissed the case, holding that the trial court correctly dismissed Respondent's case, as Respondent did not assert on appeal that the District took his property without compensation. View "W. Hardin County Consol. Indep. Sch. Dist. v. Poole" on Justia Law

The Texas Department of Criminal Justice Community Justice Assistance Division (TDCJ) brought this interlocutory appeal from the denial of its plea to the jurisdiction as to claims for damages related to actions of two county substance abuse treatment facility officers. The Supreme Court reversed and rendered judgment dismissing the claims against TDCJ for want of jurisdiction, holding (1) the claims against TDCJ based on the use of tangible property involved intent to accomplish intentional torts, and its plea to the jurisdiction as to those claims should have been granted; and (2) TDCJ's plea as to the remaining claims also should have been granted because there was no allegation that those claims resulted from the use of tangible property. View "Tex. Dep't of Criminal Justice v. Campos" on Justia Law