Justia Texas Supreme Court Opinion Summaries

In this appeal from a summary judgment dismissal of a direct and collateral attack, Petitioner contended that the underlying judgment was void and subject to collateral attack at any time. In this regard, Petitioner argued that the trial court rendering the default judgment never acquired personal jurisdiction over it because the service of process was defective. Alternatively, Petitioner argued that its adversary's extrinsic fraud prevented it from learning about the underlying default judgment and that limitations was thereby tolled, making its direct attack through a bill of review timely. The court of appeals affirmed the summary judgment, concluding that the underlying default judgment was not void and that there was no evidence of extrinsic fraud that would toll limitations. The Supreme Court reversed, holding (1) the alleged defects in service of process were not sufficient to render the default judgment void, but (2) summary judgment was improperly granted because there was some evidence of extrinsic fraud. Remanded. View "PNS Stores, Inc. v. Rivera" on Justia Law

An employee (Employee) of the Austin Independent School District (AISD), a self-insured governmental entity, was injured on the job. AISD acknowledged that Employee had been injured but disputed whether the compensable injury extended to two alleged conditions. A hearing officer sided with Employee on the contested issues, as did the administrative appeals panel. In the district court, Employee filed a counterclaim seeking attorney fees. AISD filed a nonsuit, leaving only the counterclaim for fees. After a jury trial, Employee won a judgment on the verdict that included pre-nonsuit and post-nonsuit attorney fees. The court of appeals found (1) the evidence was sufficient to support the pre-nonsuit fee award, but (2) the post-nonsuit fee award could not stand. AISD brought a petition for review in the Supreme Court, arguing for the first time that governmental immunity from suit barred the award of attorney fees. The Supreme Court reversed in part, holding (1) the defense of sovereign immunity may be raised for the first time on appeal; and (2) AISD was immune from Employee's claim for attorney fees. View "Manbeck v. Austin Indep. Sch. Dist." on Justia Law

At issue in this case was whether, for purposes of Tex. Civ. Prac. & Rem. Code Ann. 16.068, an action for cargo damage against a common carrier, brought under the Carmack Amendment to the Interstate Commerce Act, relates back to an action for breach of an agreement to settle the cargo-damage claim. The answer depended on whether the cargo-damage claim was, in the words of section 16.068, "wholly based on a new, distinct, or different transaction or occurrence" than the breach-of-settlement claim. A divided court of appeals held that the cargo-damage claim did not relate back and was therefore barred by limitations. The Supreme Court reversed and rendered judgment for the plaintiff, holding that the cargo-damage claim and the breach-of-settlement claim both arose out of the same occurrence, and therefore, the cargo-damage claim was not barred by limitations. View "Lexington Ins. Co. v. Daybreak Express, Inc." on Justia Law

In this primary election case, Choco Meza, chair of the county democratic party, determined that petitions filed with Monica Caballero's application for a place on the county democratic party primary election ballot as a candidate for justice of the peace did not contain the required number of valid signatures. Caballero sued Meza, the county democratic party, and the county, and sought injunctive relief precluding them from omitting her name from the ballot. Tomas Uresti, Caballero's opponent, intervened. The trial court subsequently issued a temporary injunction effectively compelling Meza to place Caballero's name on the ballot. Uresti applied for a writ of mandamus directing the trial court to vacate its temporary injunction. The Supreme Court dismissed the petition for mandamus relief as moot, as the primary election, which Meza won, had concluded. View "In re Uresti" on Justia Law

A corporation (Infodisc) and one of its subsidiaries (M-TX) defaulted on a loan from a bank. A California court placed the borrowers in receivership to liquidate their assets securing the loan, and an ancillary receivership was opened in Texas. Meanwhile, another Infodisc subsidiary, a California corporation (M-CA), declared bankruptcy. The receiver claimed and sold property in a Texas warehouse that the Landlord alleged was not leased to Infodisc or M-TX but to M-CA. The parties disputed who the tenant was and who owned the property and fixtures in the warehouse. After the trial court rejected almost all of the Landlord's claims, the Landlord appealed. The court vacated the trial court's judgment and dismissed the case, holding that the proceedings violated the automatic stay even though M-CA was not a party to the case. The Supreme Court granted review and reversed, holding that the court of appeals should have abated the appeal to allow the application of the automatic stay to be determined by the trial court in the first instance. Remanded. View "Evans v. Unit 82 Joint Venture" on Justia Law

This case involved a dispute over the fair market value of acreage on which a gas processing facility was located. At issue was whether the trial court abused its discretion by admitting an expert's testimony that allegedly violated the value-to-the-taker rule, which prohibits measuring land's value by its unique value to a condemnor in determining a landowner's compensation. The court of appeals concluded that the trial court did not abuse its discretion. The Supreme Court reversed, holding that the expert's testimony violated the rule because it impermissibly focused on the condemnor's interest in retaining the property and was therefore inadmissible. Remanded. View "Enbridge Pipelines L.P. v. Avinger Timber, LLC" on Justia Law

The City notified a building owner that her property was in disrepair and that, unless she repaired it, the City might demolish it. After the owner failed to remedy the problem, the City declared the property a public nuisance and condemned it. Rather than appeal the nuisance determination, the property owner asserted a takings claim after the demolition. The City field an immunity-based plea to the jurisdiction, which the trial court granted. The court of appeals reversed in part, holding that the administrative-level decision to demolish the owner's property did not preclude her from seeking a de novo review of that decision in a constitutional suit. The Supreme Court reversed in part and rendered judgment dismissing the owner's claims, holding that because the owner never appealed her nuisance determination, her takings claims were barred, and the trial court correctly dismissed them. View "City of Beaumont v. Como" on Justia Law

At issue in this case was whether mere statements of intent to discontinue a joint venture cause automatic dissolution of the venture as a matter of law. Plaintiff sued Defendant for breach of an oral agreement, alleging that Defendant promised to transfer his interest in the venture to Plaintiff. Defendant denied the existence of this contract. The trial court granted summary judgment in favor of Plaintiff. The court of appeals affirmed, reasoning that Defendant's communications to Plaintiff were conclusive evidence of dissolution of the joint venture and warranted summary judgment on the basis that Defendant lacked standing to assert any claims to the venture. The Supreme Court reversed, holding that because Defendant produced evidence creating a genuine issue of material fact as to his intent to dissolve the partnership, the court of appeals erred in affirming summary judgment on that basis. Remanded. View "Buck v. Palmer" on Justia Law

After being seriously injured in an accident by a U-Haul truck, Plaintiff sued several U-Haul corporate entities and an independent dealer on theories of negligence and gross negligence, alleging that the accident was the result of a systematic pattern of poor inspection and repair practices, and incompetence. A jury found U-Haul International (UHI) and U-Haul Company of Texas (UHT) both negligent and grossly negligent and East Fork Enterprises negligent. The trial court awarded approximately $45 million in damages, including more than $23 million in punitive damages against UHI and UHT. The court of appeals reversed the trial court's exemplary damages award against UHI and affirmed in all other respects. The Supreme Court (1) reversed the court of appeals and remanded the negligence claims for a new trial against all defendants, as the admission of certain evidence was an abuse of discretion that probably led to the rendition of an improper verdict; and (2) rendered a take nothing judgment on the gross-negligence claims against UHI and UHT. Remanded for a new trial on the negligence claims against the defendants. View "U-Haul Int'l, Inc. v. Waldrip" on Justia Law

In this health care liability claim, the trial court denied Rusk State Hospital's challenge to the plaintiffs' expert reports. The hospital filed an interlocutory appeal from that ruling. On appeal, the hospital, for the first time, asserted it was immune from suit. The court of appeals refused to consider the immunity issue because it had not been presented to the trial court. After addressing the merits of the hospital's challenge to the expert reports, the court of appeals remanded the case to the trial court for further proceedings. The Supreme Court affirmed, holding (1) the court of appeals erred by refusing to consider the immunity claim because immunity from suit implicates courts' subject-matter jurisdiction; but (2) the case was properly remanded, as (i) the pleadings and record neither established a waiver of the hospital's immunity nor conclusively negated such a waiver, and (ii) the hospital had not shown conclusively that either the plaintiffs had a full, fair opportunity in the trial court to develop the record as to immunity and amend their pleadings, or that if the case was remanded and the plaintiffs were given such an opportunity they could not show immunity had been waived. View "Rusk State Hosp. v. Black" on Justia Law