Justia Texas Supreme Court Opinion Summaries

A jury found petitioner committed sexual assault of a child based on the testimony of two witnesses who have recanted, and sentenced petitioner to 22 years' confinement after hearing false testimony by a State's expert. The district court denied habeas relief, the court of appeals affirmed, and petitioner subsequently appealed. The court concluded that petitioner was not entitled to relief on his claims of actual innocence or ineffective assistance of counsel. The court concluded, however, that false testimony by the State's expert witness contributed to his sentence and he was therefore entitled to a new disposition hearing. View "In the matter of M.P.A." on Justia Law

Relator sought compensation from the state following the Texas Court of Appeals' grant of habeas relief. Under the Tim Cole Act, Tex. Civ. Prac. & Rem. Code 103.001(a), a wrongfully imprisoned person could seek compensation from the state for the period of wrongful imprisonment. The court conditionally granted the petition for mandamus and instructed the Comptroller to comply and compensate relator under the terms of the Act where the Court of Criminal Appeals granted habeas relief on a Schlup v. Delo claim and relator's order clearly indicated that relief was based on actual innocence. View "In re Allen" on Justia Law

Plaintiff brought this suit against defendant alleging negligence in the treatment of Ronnie Young. At issue was whether the presumed harm analysis applied to a broad-form submission in a single-theory-of-liability case when the negligence charge included both an improper defensive theory of contributory negligence and an improper inferential rebuttal instruction. The court held that it did not and that meaningful appellate review was provided through a traditional harm analysis. Inasmuch as the court of appeals ruled otherwise, the court reversed the judgment and remanded for further consideration. View "Venkateswarlu Thota, M.D., et al. v. Young" on Justia Law

Plaintiff brought a wrongful termination claim against his employer under Sabine Pilot Service, Inc. v. Hauck, seeking lost wages, mental anguish damages, and exemplary damages. This case required the court to clarify the nature and scope of the cause of action for wrongful termination of an employee for refusing to perform an illegal act that the court recognized in Sabine Pilot. At issue was whether a plaintiff in a Sabine Pilot action could recover punitive damages, and if so, what must be shown as to a prerequisite for those damages. The court agreed with the court of appeals' conclusion that a Sabine Pilot cause of action sounded in tort and allowed punitive damages upon proper proof. However, because the court held that plaintiff failed to present legally sufficient evidence of malice relating to his firing, the court reversed the court of appeals' judgment insofar as it affirmed the award of exemplary damages. View "Safeshred, Inc. v. Martinez, III" on Justia Law

This appeal stemmed from litigation between a homeowner, its insurer, and the company hired to restore the home after a series of storms caused damage to the home. A jury found in the restoration company's favor and the trial court rendered judgment against the homeowner and its insurer, jointly and severally. The court of appeals affirmed in part and reversed in part. The court affirmed the court of appeals' judgment with respect to the homeowner's state Deceptive Trade Practices Act (DTPA), Tex. Bus. & Com Code 17.50, claim because the homeowner was not a prevailing party and he was not a entitled to an order restoring all amounts paid under the contracts without deducting the value received under those agreements. The court also affirmed the restoration company's charge error complaint. The court reversed the court of appeals' judgment as to the insurer where the insurer received direct consideration for its promise to pay for the dehumidification and the court of appeals erred in concluding otherwise. The court remanded for that court to consider the insurer's remaining arguments, which included challenges to the factual sufficiency of the evidence supporting the jury findings. View "Dr. Erwin Cruz v. Andrews Restoration, Inc., et al." on Justia Law

This case arose from respondent's injury on the job and the arbitration agreement he signed as a condition of his employment. At issue was whether an appellate court had jurisdiction over an appeal from a trial court order confirming an arbitration award in part and vacating the award in part based on the existence of unresolved questions of law or fact necessary to a ruling, yet the trial court did not expressly direct a rehearing. Because the order left significant factual and legal issues open for further determination, it was interlocutory and not appealable unless authorized by statute. Accordingly, the court of appeals and the court did not have jurisdiction over the interlocutory appeal. View "Bison Building Materials, Ltd., v. Aldridge" on Justia Law

This was an appeal from a judgment awarding tenant damages for a landlord's breach of a construction-related duty under a build-to-suit lease agreement. The tenant sued asserting that the landlord's failure to adhere to construction plans resulted in a substandard building, diminishing the value of its leasehold. On appeal, the court agreed with the landlord that the cost of repair was the appropriate measure under the circumstances of the case. Because under the appropriate measure, there was no evidence that the tenant had been damaged, the court reversed. View "Ashford Partners, Ltd. v. ECO Resources, Inc." on Justia Law

Pursuant to article V, section 3-c of the Texas Constitution and Texas Rule of Appellate Procedure 58.1, the court accepted the petition from the United States Court of Appeals for the Fifth Circuit to answer three certified questions. The central issue in this case was one of first impression: whether private beachfront properties on Galveston Island's West Beach were impressed with a right of public use under Texas law without proof of an easement. The court concluded that land patents from the Republic of Texas in 1840, affirmed by legislation in the New State of Texas a few years later, conveyed the State's title in West Galveston Island to private parties and reserved no ownership interests or rights to public use in Galveston's West Beach. Texas law had not otherwise recognized such an inherent limitation on property rights along the West Beach. Accordingly, there were no inherent limitations on title or continuous rights in the public since time immemorial that served as a basis for engrafting public easements for use of private West Beach property. Although existing public easements in the dry beach of Galveston's West Beach were dynamic, these easements did not spring or roll landward to encumber other parts of the parcel or new parcels as a result of avulsive events. New public easements on the adjoining private properties could be established if proven pursuant to the Open Beaches Act, Tex. Nat. Res. Code 61.001(8) or the common law. View "Severance v. Patterson, et al." on Justia Law

This case involved a dispute over fees awarded to an ad litem appointed in connection with the proposed division of a personal injury settlement between an incapacitated plaintiff and his guardian. The court-appointed attorney requested fees on an unsworn invoice that specified numerous tasks performed, but did not specify when they were performed, who performed them, or the amount of time spent. The court held that the evidence was legally insufficient to support the full amount awarded to the guardian ad litem (GAL) as compensation, although it was sufficient to show that he necessarily spent some amount of time fulfilling his role as GAL. The court reversed the judgment of the court of appeals and remanded the case to the trial court for further proceedings. View "Ford Motor Co. v. Garcia" on Justia Law

Plaintiff and her son were injured when her car was struck by a pickup truck driven by Edward Cantu. MCAA employed Cantu and Puckett owned the truck. Cantu's negligence was stipulated. The jury found that, although MCAA was his employer, Cantu drove the vehicle for Puckett's benefit. The jury found that MCAA, as Cantu's employer, had the right to direct the details of his work. It also found that Cantu was subject to Puckett's control "as to the details of the mission" when the accident occurred. The trial court rendered judgment for plaintiff. The court of appeals remanded for a new trial, holding that a jury could not logically find MCAA and Puckett to have simultaneously controlled Cantu's conduct, as the trial court had instructed the jury that Cantu could not have been an employee of both. But the jury also found that MCAA was subject to Puckett's control and was on a mission for Puckett's benefit - which comprised the elements of a principal-agent relationship. MCAA was vicariously liable for its employee's negligence; Puckett as principal was responsible for its agent's conduct. Because it was able to reconcile the jury's answers on that agency theory, the court reversed the court of appeals' judgment. View "Arvizu, et al. v. The Estate of George Puckett" on Justia Law