Justia Texas Supreme Court Opinion Summaries

Respondent injured his back while working, and his employer's workers' compensation insurer, Texas Mutual Insurance Company (TMIC), accepted the injury as compensable. Three years later when it was discovered that Respondent had herniated lumbar intervertebral discs, TMIC disputed whether they were causally related to the original injury. The Texas Department of Insurance Division of Workers' Compensation determined that the disc herniations were related to the original injury and ordered TMIC to pay medical benefits, which it did. Respondent later sued TMIC for damages caused by its delay in paying benefits. The trial court rendered judgment for Respondent, and the court of appeals affirmed. Based on the Court's recent decision in Texas Mutual Insurance Co. v. Ruttiger, the Supreme Court reversed and rendered judgment for TMIC. View "Tex. Mut. Ins. Co. v. Morris" 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

This case was before the Supreme Court a second time and concerned a business dispute between Rancho La Valencia, Inc. and Aquaplex, Inc. In the earlier appeal, the Court held that the evidence of fraudulent intent by Rancho in connection with the execution of a memorandum of settlement agreement was legally sufficient but that the evidence did not support damages to the level awarded by the trial court. On remand, the court of appeals remanded the case to the trial court for a new trial on the issue of damages. Rancho appealed, complaining that the court of appeals should have remanded the case for a new trial on both liability and damages, as Rancho requested in a motion for rehearing to the court of appeals. The Supreme Court agreed, holding that Tex. R. App. P. 44.1 required the court of appeals to remand for a new trial on both liability and damages. Remanded. View "Rancho La Valencia, Inc. v. Aquaplex, Inc." on Justia Law

At issue in this case was whether taxpayers who were sued for nonpayment of property taxes lost their entitlement to contest liability based on non-ownership when the taxing authorities non-suited after the taxpayers paid the disputed taxes under protest. The taxing authorities filed a plea to the jurisdiction, asserting that the district court lacked jurisdiction because the taxpayers failed to exhaust administrative remedies as required by the Tax Code. The district court denied the plea. The court of appeals reversed and granted the plea. The Supreme Court reversed, holding that the taxpayers did not lose their entitlement to contest tax liability on the basis of non-ownership when the taxing units non-suited and the taxpayers were realigned as plaintiffs. View "Morris v. Houston Indep. Sch. Dist." on Justia Law

This appeal arose from a suit by ExxonMobil Corporation against DSTJ, LLP and Milestone Operating, Inc. (collectively Milestone). After Milestone failed to answer, ExxonMobil obtained a default judgment. Milestone appealed, arguing that service on Donald Harlan - DSTJ's partner and Milestone Operating, Inc.'s director and registered agent - was defective, and that Milestone established the necessary elements set forth in Craddock v. Sunshine Bus Lines, Inc. to set aside the default judgment. The trial court denied the motion for new trial. The court of appeals affirmed, holding that Milestone failed to meet its burden to satisfy Craddock's first element. The Supreme Court reversed and remanded, holding that because the evidence in this case established that Defendants' failure to answer was no intentional or the result of conscious indifference, Defendants' motion for new trial could not be denied on the ground that Defendants failed to satisfy the first Craddock element. Remanded. View "Milestone Operating, Inc. v. ExxonMobil Corp." on Justia Law

At issue in this case was whether a non-hurricane windstorm case could be joined as a tag-along to a previously created pre-trial Hurricane Ike multidistrict litigation (MDL) court. A single pretrial judge remanded this case because it did not arise from a hurricane. The Supreme Court granted the motion for rehearing and vacated the single pretrial judge's order of remand, holding (1) the case was related to the MDL litigation because the issue of whether State Farm covered shingle damage arising from wind events during the period between 2008 and 2010 was common to all cases; and (2) transfer would promote efficiency and serve the convenience of parties and witnesses. View "In re State Farm Lloyds Hurricane Litig." on Justia Law

Since first imposing a franchise tax in 1893, the Legislature restructured it several times, drawing various distinctions among taxpayers with adjustments, deductions, and exemptions that became elaborate. Petitioner in this original proceeding contended that the franchise tax bore no reasonable relationship to its object, the value of the privilege of doing business in Texas, and therefore it violated the Texas Constitution's mandate that "taxation shall be equal and uniform," the Fourteenth Amendment's equal protection and due process guarantees, and the U.S. Constitution's Commerce Clause. The Supreme Court denied the petition, holding (1) Petitioner failed to establish that the franchise tax violates the Equal and Uniform Clause; (2) the failure of Petitioner's challenge based on the Equal and Uniform Clause foreclosed its equal protection challenge; (3) the franchise tax does not violate due process; and (4) the manufacturing rate does not discriminate against interstate commerce and is fairly related to the services provided by Texas. View "In re Nestle USA, Inc." on Justia Law

G.W., David Gray and Lucy Wood's nine-year-old daughter, had lived with her maternal grandmother, Ann Shook, for her entire life. The trial court appointed Shook as G.W.'s sole managing conservator and named Gray and Wood as G.W.'s possessory conservators. The court of appeals reversed, holding that the trial court abused its discretion in naming Shook, a nonparent, as G.W.'s sole managing conservator because Shook failed to present any evidence that could overcome the presumption that a parent should be named as managing conservator. The court then remanded the case to the trial court to determine the custody and visitation rights as between Gray and Wood only. The Supreme Court affirmed the court of appeals' judgment remanding the case but reversed to the extent the judgment limited the trial court's consideration of the role Shook should play in G.W.'s life, whether as conservator or a person with defined access rights. View "Shook v. Gray" on Justia Law

In this employer retaliation case, a broad-form jury question allowed the jury to find liability based on a legal theory that was jurisdictionally barred and thus could not support liability. The trial court entered a judgment reinstating Employee to her position and awarding her damages and attorney's fees. Employer appealed, arguing that the jury charge allowed a finding of liability based on invalid legal theories. The court of appeals concluded that Employer waived its objection. The Supreme Court reversed, holding (1) Employer properly preserved its objection; and (2) because the Court could not determine whether the jury relied on the invalid theory, the case was remanded for a new trial. View "Tex. Comm'n on Human Rights v. Morrison" on Justia Law