Justia Texas Supreme Court Opinion Summaries

Plaintiff, a professor at the University of Houston, sued the University under the Texas Whistleblower Act. Plaintiff alleged that the University retaliated against him for reporting that his supervisor violated state civil and criminal law and internal administrative policies located in the University's System administrative Memorandum (SAM). The trial court rendered judgment in favor of Plaintiff. The court of appeals affirmed, holding that the trial court had subject-matter jurisdiction over Plaintiff's claim because the SAM's administrative policies constitute "law" under the Whistleblower Act. The Supreme Court reversed and dismissed for lack of subject-matter jurisdiction, holding (1) the SAM's administrative rules do not fall within the definition of "law" under the Whistleblower Act because there is no evidence the University's Board of Regents enacted the SAM's administrative rules pursuant to authority granted to it in the Texas Education Code; (2) there was no evidence that Plaintiff had an objectively reasonable belief that his reports of the alleged violations of state civil and criminal law were made to an appropriate law enforcement authority; and (3) therefore, the University's sovereign immunity was not waived in this case. View "Univ. of Houston v. Barth" on Justia Law

Mother was seen punching and dragging her four-year-old daughter (Daughter) by her ponytail down the street. Mother's eight-month-old son (Son) was not present during the incident. The police arrested Mother, who later pleaded guilty to bodily injury to a child. The Department of Family and Protective Services took possession of Son under Tex. Fam. Code Ann. 262.104 because he faced a "continuing danger to his physical health or safety" if returned to Mother. Later, the trial court terminated Mother's parental rights to Son under Tex. Fam. Code Ann. 161.001(1). The court of appeals reversed, holding (1) for a trial court to terminate parental rights under section 161.001(1)(O), it must find the child who was the subject of the suit was removed as a result of the abuse or neglect of that specific child; and (2) Mother's abuse of Daughter was not evidence that Mother abused or neglected Son. The Supreme Court reversed in part, holding that abuse or neglect includes placing the child's physical health or safety at substantial risk, and the parent's abuse or neglect of another child is relevant to that determination. Remanded. View "In re Interest of E.C.R." on Justia Law

Law Firm sued Client for breach of contract, alleging that Client failed to pay its legal fees. A jury found that Client breached the agreement and awarded Law Firm damages, $150,000 as reasonable attorney's fees, and pre- and post-judgment interest. To suspend enforcement of the judgment pending appeal, Client deposited a cashier's check with the trial court, including the breach of contract damages and pre- and post-judgment interest. The trial court subsequently ordered Client to supplement the deposit to cover the attorney's fees award. The court of appeals denied Client appellate relief, concluding that attorney's fees are both compensatory damages and costs for the purpose of suspending enforcement of a judgment. The Supreme Court conditionally granted Client mandamus relief, holding that attorney's fees are neither compensatory damages nor costs for purposes of suspending enforcement of a money judgment, and directed the trial court to vacate its order and refund and monies overpaid by Client. View "In re Nalle Plastics Family Ltd. P'ship" on Justia Law

In a letter sent to colleagues and others, Defendant, a physician, accused a fellow physician, Plaintiff, of lacking veracity and speaking in half truths. The trial court granted a directed verdict that the letter was defamatory per se. A jury awarded Plaintiff $90,000 in actual damages for mental anguish and loss of reputation and $85,000 in exemplary damages. The court of appeals affirmed the damages award. The Supreme Court reversed, rendering judgment that Plaintiff taking nothing, where (1) the statements did not defame the physician per se, and thus, the Court could not presume damages for mental anguish and loss of reputation, and consequently, Plaintiff was required to prove actual damages; (2) there was no evidence of mental anguish that rose to the level of a substantial disruption in daily routine or a high degree of mental pain and distress; (3) there was no evidence of loss of reputation because there was no indication that any recipient of the defamatory letter believed in its statements; and (4) because Plaintiff did not establish actual damages, he could not recover exemplary damages. View "Hancock v. Variyam" on Justia Law

In an earlier suit, fourteen Texas hospitals filed a declaratory relief action against the Texas Health and Human Services Commission and its Executive Commissioner (collectively HHSC), challenging a cutoff date used by HHSC to cap the collection of data used to calculate Medicaid reimbursement rates for inpatient services. The Supreme Court declared the cutoff-date rule invalid and enjoined its enforcement. The Court further remanded the cause to the district court, where the hospitals argued that the Court's judgment should apply retroactively to provide them a basis to reopen their earlier administrative appeals and to seek reimbursement for the underpayment of past Medicaid claims calculated under the invalid cutoff-date rule. The district court found in favor of the hospitals. The court of appeals reversed, determining that the injunction should only operate prospectively. The Supreme Court affirmed, holding that the court of appeals correctly concluded that the Court's earlier opinion and judgment did not purport to reopen past rate determinations or closed administrative proceedings. View "El Paso County Hosp. Dist. v. Tex. Health & Human Servs." on Justia Law

Husband sued Wife for divorce and custody of their children. Wife hired Law Firm to represent her in the proceedings. After the jury verdict, Law Firm sued both Wife and Husband for its fees. After a hearing, Husband and Wife agreed that the final decree would award Law Firm attorney fees against Wife only and would not award Wife attorney fees against Husband. The trial court rendered judgment in accordance with their agreement. Wife subsequently sought the protection of bankruptcy and was discharged. Law Firm appealed. The court of appeals rendered judgment for Law Firm against Husband and Wife jointly and severally, holding that Husband was liable for Wife's Legal fees because (1) the obligation was a "community debt," and (2) the legal fees were "necessaries" for which Husband was liable to the firm. The Supreme Court reversed, holding (1) Husband was not liable to pay Law Firm for legal services rendered to Wife unless those services were necessaries; and (2) legal services provided to one spouse in a divorce proceeding are not necessaries for which the other spouse is statutorily liable to pay the attorney. View "Tedder v. Gardner Aldrich, LLP" on Justia Law

Juvenile was charged with attempted capital murder, aggravated assault on a public servant, and deadly conduct. The jury adjudicated Juvenile of aggravated assault and deadly conduct, assessing determinate sentences for forty years and ten years, respectively. The court of appeals affirmed the aggravated assault adjudication but reversed on deadly conduct, concluding that the trial court committed reversible error by submitting elements of the offense to the jury disjunctively, allowing for a non-uanimous verdict. The State appealed. The Supreme Court reversed, holding that the trial court's disjunctive jury instruction, given without objection, was not reversible error, as the harm to Juvenile, given the jury's other findings and the evidence, was only theoretical, not actual. View "In re L.D.C." on Justia Law

The beneficiary of an inter vivos trust sued the trustee for misappropriation of trust assets and failing to provide an accounting to the trust's beneficiaries. The trustee moved to compel arbitration, relying an arbitration provision contained in the trust. The trial court denied the motion. The court of appeals affirmed, concluding that the provision could not be enforced under the Texas Arbitration Act (TAA) because there was no agreement to arbitrate trust disputes. The Supreme Court reversed, holding that the arbitration provision contained in the trust was enforceable against the beneficiary, as (1) the settlor's intent here was to arbitrate any disputes over the trust; and (2) the beneficiary's acceptance of the benefits of the trust and suit to enforce its terms constituted the assent required to form an enforceable agreement to arbitrate under the TAA. Remanded. View "Rachal v. Reitz" on Justia Law

Plaintiff sued the hospital (Hospital) where she gave birth to a newborn and the two doctors who assisted in delivery, alleging that Hospital was liable for injuries to the newborn because of its own direct negligence as well as its vicarious liability for the negligence of the two doctors. Plaintiff served Hospital with three expert reports, all of which Hospital objected to. The trial court determined that when the three reports were read in concert, Plaintiff had met the requirements of the Texas Medical Liability Act (TMLA). The court of appeals concluded Plaintiff's reports were adequate as to the vicarious liability claim but remanded to the trial court to consider granting an extension to cure other deficiencies. The Supreme Court (1) affirmed the court of appeals' judgment as to the adequacy of the reports regarding the claim that Hospital was vicariously liable for the doctors' actions; and (2) did not address whether the court of appeals erred by remanding the case for the trial court to consider granting an extension of time for Plaintiff to cure deficiencies, as the expert reports satisfied the TMLA requirements as to one theory of liability alleged against Hospital. View "TTHR Ltd P'ship v. Moreno" on Justia Law

Two years after their child was born, Mother obtained a default judgment establishing Father's paternity and ordering child support to be paid until the child reached the age of eighteen. Father made child-support payments after receiving notices from the Office of the Attorney General (OAG). When the child was six years old, the OAG erroneously closed Father's case, and Father stopped making payments. Mother subsequently sought to enforce the order, and Father sought a determination of arrearages. The trial court ultimately found Father owed only $500 in arrearages. The court of appeals affirmed. The Supreme Court reversed, holding that no evidence existed to support the trial court's specific finding of $500 in arrearages, as an OAG clerical error served as a basis for modifying the child-support obligation. Remanded. View "Granado v. Meza" on Justia Law