Justia Texas Supreme Court Opinion Summaries

This case involved the duties and standard of care of an oil and gas operator under an exculpatory clause in a joint operating agreement (JOA). Based on language in the exculpatory clause in the JOA, the trial court instructed the jury to find that to find a breach of the JOA the operator's conduct must have risen to the level of gross negligence or willful misconduct. The jury found the operator, Petitioner, breached his duties under the JOA to the working interest owners. The court of appeals affirmed, holding (1) the gross negligence and willful misconduct instruction should not have been included in the charge because the case centered around a breach of contract; but (2) there was legally sufficient evidence to support the jury's findings that Petitioner breached his duty as operator when measured against the elements of breach of contract. The Supreme Court reversed, holding (1) the exculpatory clause in the JOA established the standard for the claims against Petitioner; and (2) there was legally insufficient evidence that Petitioner was grossly negligent or acted with willful misconduct. View "Reeder v. Wood County Energy, LLC" on Justia Law

Respondent, a professor at Prairie View A&M University, filed a complaint with the EEOC and the Texas Workforce Commission civil rights division (TWC), alleging race and nationality-based pay discrimination, about two years after her promotion to full professor. Respondent subsequently filed suit against the University in state court under the Texas Commission on Human Rights Act (TCHRA). The University filed a plea to the jurisdiction, asserting Respondent's complaint was untimely filed pursuant to the 180-day limitations period under the TCHRA. The trial court denied the University's plea. The court of appeals affirmed, holding that the federal Ledbetter Act, which provides that the limitations period begins anew each time a claimant receives a paycheck containing a discriminatory amount, applies to claims brought under the TCHRA, and Respondent's claim was therefore timely because she received a paycheck containing an alleged discriminatory amount within 180 days of the date she filed her complain with the TWC. The Supreme Court reversed, holding (1) the Ledbetter Act does not apply to a claim brought under the TCHRA; and (2) because Respondent failed to timely file her complaint with the TWC, her suit was jurisdictionally barred. View "Prairie View A&M Univ. v. Chatha " on Justia Law

Two female patients sued a medical doctor, the professional association bearing his name, and a clinic, alleging the doctor assaulted the patients by groping their breasts while examining them for sinus and flu symptoms. Although they maintained the claims were not health care liability claims (HCLCs), the patients served the doctor and professional association with reports from a physician who, based only on the assumption that allegations in the plaintiffs' pleadings were true opined that the defendant doctor's alleged actions did not fall within any appropriate standard of care. The trial court denied Defendants' motions for dismissal on the suit on the basis that the claims were HCLCs and that the reports were deficient. The court of appeals affirmed without considering the reports' adequacy. The Supreme Court reversed, holding (1) the Texas Medical Liability Act (TMLA) creates a rebuttable presumption that a patient's claims against a physician or health care provider based on facts implicating the defendant's conduct during the patient's care, treatment, or confinement are HCLCs; and (2) the record did not rebut the presumption as it related to the TMLA's expert report requirements, nor were the expert reports served by the plaintiffs adequate under the TMLA. Remanded. View "Loaisiga v. Cerda" on Justia Law

In Plaintiff's negligence against United Scaffolding, a jury assigned fifty-one percent responsibility for Plaintiff's injuries to United. The trial court subsequently granted Plaintiff's motion for a new trial in the interest of justice and fairness. After the trial court amended its order, United sought mandamus relief, arguing that the amended order failed to provide adequate reasoning for granting the motion for new trial. The Supreme Court conditionally granted the writ of mandamus, holding (1) because the trial court's order was premised solely "in the interest of justice," it did not provide a reasonably specific explanation of the court's reasons for setting aside the jury verdict; and (2) the trial court need not render judgment on the jury verdict. View "In re United Scaffolding, Inc." on Justia Law

Michael Wayne Bohannan pleaded guilty to two counts of aggravated rape with a deadly weapon. Upon being released on mandatory supervision, Bohannan was thrice returned to prison for sexual crimes. After receiving a psychologist's report that Bohannan was a sexually violent predator (SVP), the State petitioned for his commitment. After a jury trial, the trial court issued an order of civil commitment. Bohannan appealed, contending that the trial court's exclusion of certain testimony on the basis that the expert was "not qualified to present an opinion" on whether someone is an SVP was error. The court of appeals determined that the exclusion of the testimony was harmful error and remanded the case for a new trial. The Supreme Court affirmed, though for different reasons, holding that the trial court abused its discretion in excluding the testimony on the grounds that the expert was not a physician or psychologist rather than examining her experience and training, and the exclusion was harmful. View "In re Commitment of Bohannan" on Justia Law

As tasked by the Legislature, the Texas Water Development Board (TWDB) identified potential reservoir sites. Hearts Bluff Game Ranch, Inc. purchased some of the wetlands on one of the sites identified by the TWDB as a potential reservoir location. When the U.S. Army Corps of Engineers denied its application for a mitigation banking permit because the State had identified the site as a potential reservoir, Hearts Bluff sued the State and the Corps for a taking for interfering with its asserted right to commercially develop the land as a mitigation bank. At issue was whether a takings claim against the State may be predicated on the denial of a permit by the federal government when the State had no authority to grant or deny the permit. The trial court denied the State's plea to the jurisdiction, which alleged that Hearts Bluff failed to plead a valid takings claim. The court of appeals reversed. The Supreme Court affirmed, holding that absent demonstrating bad faith, Hearts Bluff did not establish the existence of jurisdiction in this case because it did not establish a viable takings claim. View "Hearts Bluff Game Ranch, Inc. v. State" on Justia Law

This was an appeal from the City of Austin's condemnation of property to build a parking garage for a nearby convention center and a facility to chill water to cool nearby buildings. A jury found the City's determination that the property was necessary for public use was fraudulent, in bad faith, and arbitrary and capricious, and the trial court entered judgment on the verdict, invalidating the taking. The court of appeals affirmed. The Supreme Court reversed, holding that the City's determination that the property was necessary for public use was not fraudulent, in bad faith, or arbitrary and capricious. Remanded. View "City of Austin v. Whittington" on Justia Law

The Texas Tort Claims Act imposes a lesser duty of care on the government when a premises liability claim does not involve a special defect. Plaintiff sued City, claiming that its negligence in creating and failing to repair, or warn of, a street's dangerous condition caused her to have an accident while bicycling. City moved for summary judgment, arguing that the street's condition was not a special defect but rather an ordinary premises defect of which Plaintiff was aware and the City was not. The trial court denied the motion, concluding that the condition was a special defect. The court of appeals affirmed. The Supreme Court reversed and dismissed the case, holding (1) the condition in this case was not a special defect; and (2) City was not liable for an ordinary premises defect because Plaintiff had no evidence that City knew about this hazard before her accident. View "City of Denton v. Paper" on Justia Law

The issue in this case was whether an appellate court has 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. The court of appeals held that it did not have jurisdiction over the appeal, holding (1) the judgment was not final because it did not contain finality language or otherwise state that it was a final judgment and necessarily contemplated resolution of the remaining issues by way of a rehearing, and therefore, the appeal was interlocutory; and (2) no statute permitted an appeal in this case. The Supreme Court affirmed and, for different reasons, dismissed the appeal for want of jurisdiction, holding (1) the appeal was interlocutory; (2) the Texas Arbitration Act did not provide jurisdiction over the interlocutory appeal; and (3) there is no jurisdiction over arbitration awards that are incomplete unless, under certain circumstances, the parties file a writ of mandamus, which neither party here filed. View "Bison Bldg. Materials, Ltd. v. Aldridge" on Justia Law

At issue in this interlocutory appeal was whether the claims of an employee against his employer, both of whom were health care providers, alleging injuries arising out of inadequate training, supervision, risk-mitigation, and safety in a mental health facility, constituted health care liability claims (HCLCs) under the Texas Medical Liability Act (Act). Employer filed a motion to dismiss on the grounds that Employee's claims constituted HCLCs under the Act and that Employee had not served an expert report on Employer as required under the Act. The trial court denied Employer's motion. The trial court affirmed. The Supreme Court reversed, holding (1) Employee here was properly characterized as a "claimant" under the Act and his allegations against his nonsubscribing Employer were health care and safety claims under the Act's definition of HCLCs, requiring an expert report to maintain his lawsuit; and (2) the Act does not conflict with the Texas Workers' Compensation Act. Remanded. View "Tex. W. Oaks Hosp., LP v. Williams " on Justia Law