Justia Texas Supreme Court Opinion Summaries

In this eminent domain dispute, the Supreme Court affirmed in part and reversed in part the decision of the court of appeals affirming in part and reversing in part the trial court's judgment in favor of a pipeline company, holding that remand was required for a new trial to determine the market value of the property taken.A landowner challenged the pipeline company's right to condemn, arguing that the transport of polymer-grade propylene did not the pipeline company common-carrier status. After excluding the landowner's evidence of sales of other pipeline easements the trial court found in favor of the pipeline company. The court of appeals reversed in part, holding that whether the pipeline served a public use presented a fact question for a jury to resolve and that the trial court erred in excluding the landowner's testimony about easement sales. The Supreme Court reversed in part, holding (1) Tex. Bus. Org. Code 2.105 grants common-carrier eminent domain authority for the construction and use of a polymer-grade propylene pipeline; (2) the company demonstrated that its pipeline served a public use, and that determination is a legal one; and (3) a property owner may testify to sales of pipeline easements across the property made to other pipeline carriers. View "Hlavinka v. HSC Pipeline Partnership, LLC" on Justia Law

The Supreme Court held that the Texas Commission on Environmental Quality's (TCEQ) general jurisdiction over water and water rights, including the issuance of water rights permits and water rights adjudication, does not include the authority to adjudicate conflicting claims to ownership of surface-water rights.Plaintiff brought this complaint seeking declarations that it was the sole owner of certain surface-water rights. Defendant filed a motion to dismiss the claims for lack of subject-matter jurisdiction, arguing that TCEQ has exclusive original jurisdiction to determine water-ownership rights. The trial court granted the motion to dismiss and the court of appeals affirmed. The Supreme Court reversed, holding that TCEQ lacks jurisdiction to decide conflicting claims of ownership to surface-water rights and that the adjudication of such claims is for the courts. View "Pape Partners, Ltd. v. DRR Family Properties LP" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the trial court's grant of summary judgment for the current owners of certain property, holding that Elizabeth Mitchell's due process rights were violated in a 1999 suit in which the court entered a default judgment foreclosing a tax lien on Elizabeth's interest.After Elizabeth died in 2009, her heirs (Petitioners) brought suit to declare void the 1999 default judgment, alleging the judgment violated Elizabeth's constitutional right to procedural due process because Elizabeth was not properly served with notice of the underlying foreclosure suit. Respondents, the current owners of the property who purchased it at a tax sale or later acquired an interest in it, argued that the publicly recorded warranty deeds and county tax records could not be considered in this collateral attack. The trial court agreed and granted summary judgment for Respondents. The court of appeals affirmed. The Supreme Court reversed, holding (1) information available in relevant public records can be considered in a collateral attack on a judgment that alleges constitutional due process violations; and (2) Petitioners established that Elizabeth was not properly served in the 1999 suit, and therefore, the court in the tax foreclosure suit did not acquire personal jurisdiction over Elizabeth. View "Mitchell v. MAP Resources, Inc." on Justia Law

In this dispute over a family ranch the Supreme Court affirmed in part and reversed in part the judgment of the court of appeals reversing in part the district court's rejection of Plaintiffs' claims on summary judgment, holding that Kenneth Berry's claims were properly rejected by the district court but that Chelsea Berry's claims should have been allowed to proceed.Kenneth and his daughter Chelsea filed this suit alleging that Defendants did not pay for the use of the ranch and that a lease between the parties was impermissibly long. The district court granted summary judgment for Defendants on all claims. The court of appeals affirmed the dismissal of Chelsea's claims and some of Kenneth's claims but reversed as to Kenneth on a statute of limitations issue. The Supreme Court reversed in part, holding that the district court (1) properly disposed of all of Kenneth's claims; but (2) erred in dismissing Chelsea's claims. View "Berry v. Berry" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the judgment of the trial court against Landlord and in favor of the City of Baytown in this dispute over unpaid utility bills, holding that Landlord's challenge to the City's enforcement action failed to show the intentional taking or damage for public use necessary to establish a constitutional right to compensation.In this action, Landlord alleging that the City's withholding of utility service to collect payment resulted in the loss of a tenant and the disrepair of his property and was a taking in violation of the state or federal constitution. The trial court concluded that Landlord did not establish an intentional taking of private property for public use. The court of appeals reversed. The Supreme Court reversed, holding that the City's utility enforcement actions did not establish a regulatory taking of private property as a matter of law. View "City of Baytown v. Schrock" on Justia Law

In this oil and gas case, the Supreme Court reversed the judgment of the court of appeals reversing the trial court's summary judgment, holding that a fact issue remained on Plaintiffs' claim for breach of the lease and that Plaintiffs' argument was not barred by res judicata but that the court of appeals erred by reversing a take-nothing summary judgment as to Plaintiffs' tort and statutory claims.At issue was the meaning and application of an express covenant to protect against drainage that appeared in a lease addendum that expressly limited the location of wells that may trigger Defendant-Lessee's obligation to protect against drainage but did not directly address the location of wells that may cause drainage. Plaintiffs-Lessors argued that the covenant allowed for separate triggering and draining wells and that Defendant breached the covenant by failing to protect against drainage from a non-triggering well. In response, Defendant argued that it had a duty to protect only against drainage from the limited class of triggering wells. The Supreme Court held (1) the addendum was ambiguous because both interpretations of the covenant were reasonable; (2) the court of appeals improperly reversed the trial court's take-nothing summary judgment on Plaintiffs' tort and statutory claims; and (3) remand was required for further proceedings on Plaintiffs' claim for breach of the lease. View "Rosetta Resources Operating, LP v. Martin" on Justia Law

In this dispute between a homeowners' association and a townhome owner the Supreme Court reversed the opinion of the court of appeals affirming the judgment of the trial court enjoining the owner from renting its townhomes for terms of fewer than seven days, holding that the association had no authority to impose a short-term rental restriction.After the association demanded that the owner stop leasing its townhomes for short-term rentals the owner sued to enforce a covenant in the neighborhood's deed restrictions granting it the right to lease without restriction. The trial court ruled that the short-term rentals breached a provision in the neighborhood's deed restrictions. The court of appeals affirmed, concluding that the association possessed independent authority under Tex. Prop. Code 204.010(a)(6) to restrict short-term rentals. The Supreme Court reversed, holding that neither the deed covenants nor the Property Code authorized the association to impose a short-term rental restriction. View "JBrice Holdings, LLC v. Wilcrest Walk Townhomes Ass'n" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the judgment of the trial court, rendered pursuant to a jury verdict, that Stephen Stelly owned real property free of any encumbrance, holding that Stelly adequately pleaded a trespass-to-try-title claim.Stelly brought this action against John DeLoach claiming that DeLoach had breached the parties' contract by not delivering a real property deed after Stelly had paid off the debt on the land's original purchase price.The jury entered a verdict in favor of Stelly. The court of appeals reversed, concluding that Stelly pleaded only a breach-of-contract claim, not a trespass-to-try-title claim and that the statute of limitations had run on Stelly's breach of contract claim. The Supreme Court reversed and remanded the case for further proceedings, holding that Stelly adequately pleaded a trespass-to-try-title claim. View "Stelly v. DeLoach" on Justia Law

In this premises-defect case, the Supreme Court denied the petition for writ of mandamus brought by Eagleridge Operating, LLC seeking relief from a trial court order striking its responsible-third-party designation under Chapter 33 of the Texas Civil Practice and Remedies Code, holding that Eagleridge failed to establish that it was entitled to the writ.In this action, Eagleridge argued that a former well site owner-operator bore continuing responsibility for injuries caused by a burst gas pipeline because the former owner acted as an independent contractor in constructing, installing, and maintaining the pipeline. The lower courts concluded that Occidental Chemical Corp. v. Jenkins, 478 S.W.3d 640 (Tex. 2016), was controlling and that the former owners' responsibility for premises defects did not survive the conveyance of its ownership interest. The Supreme Court agreed, holding that an agreement between tenants in common to allocate expenses, assign responsibilities, and compensate for disparate efforts in a joint endeavor does not create an exception to Occidental as to improvements each party would otherwise have been free to construct without the consent of the other. View "In re Eagleridge Operating, LLC" on Justia Law

The Supreme Court held that a negligence claim can arise from the condition or use of an improvement even when negligence elsewhere is alleged to have contributed to a plaintiffs' injuries so long as the other statutory requirements are satisfied.Plaintiffs brought claims for negligence, gross negligence, and trespass to chattels against Defendant, the owner of property upon which Plaintiffs were working to drill a water well. Plaintiffs brought this action alleging that there was negligence regarding a condition of the water well Plaintiffs were drilling, and this negligence caused damages. Defendant filed a motion for summary judgment, asserting that Chapter 95 of the Civil Practice and Remedies Code applied to Plaintiffs' claims. The trial court granted the motion. The court of appeals reversed. The Supreme Court reversed, holding (1) Chapter 95 applied; and (2) the trial court properly granted summary judgment because Defendant proved conclusively that it could not be held liable under Chapter 95 given its lack of control over the work. View "Energen Resources Corp. v. Wallace" on Justia Law