Justia Texas Supreme Court Opinion Summaries

Respondents obtained a home-equity loan from Wells Fargo Bank. After Respondents stopped making loan payments, Wells Fargo filed an application in the district court for an expedited court order authorizing foreclosure. Respondents filed a separate and original declaratory judgment action that invoked the automatic stay and dismissal provisions of Tex. R. Civ. P. 736.11. Wells Fargo filed an amended answer asserting a counterclaim for declaratory judgment and requesting attorney’s fees pursuant to the Uniform Declaratory Judgments Act. The trial court granted Wells Fargo’s motion for summary judgment and awarded attorney’s fees, concluding that Respondents had defaulted on their home-equity loan. The court of appeals affirmed the trial court’s summary judgment but reversed the attorney’s fee award, concluding that neither party had pleaded a cognizable claim for declaratory relief, and the non-recourse status of the home-equity loan prohibited a personal judgment for attorney’s fees against Respondents. The Supreme Court reversed in part, holding (1) because Respondents failed to preserve any challenge to the characterization of their own claim for declaratory relief, the trial court was authorized to enter a judgment awarding Wells Fargo its attorney’s fees; and (2) neither the parties’ loan agreement nor the Texas Constitution prohibited a personal judgment against Respondents for attorney’s fees. View "Wells Fargo Bank, N.A. v. Murphy" on Justia Law

This case arose from the deadly collision of two eighteen-wheeled commercial trucks. Petitioner filed this third-party claim against Fayette County, alleging that the collision was caused by a County deputy sheriff. Petitioner sought redress pursuant to Tex. Civ. Prac. & Rem. Code 101.021, which provides a waiver of governmental immunity when an injury “arises from the operation or use” of a vehicle by a government employee. The trial court sustained the County’s plea to the jurisdiction, concluding that the county remained immune from suit because the accident did not arise from a government employee’s vehicle use. The Supreme Court reversed, holding that Petitioner alleged an injury arising from a deputy sheriff’s vehicle use for the purpose of section 101.021. View "Ryder Integrated Logistics, Inc. v. Fayette County" on Justia Law

Plaintiff, a mineral owner, sued Defendant alleging breach of contract, failure to pay royalties, and fraud. The claims centered on three oil and gas leases that Plaintiff, the lessor, executed with Defendant, the lessee. Plaintiff prevailed on the majority of his claims in the trial court. As relevant to this appeal, the jury determined that Plaintiff, in the exercise of reasonable diligence, discovered the fraud less than four years before filing suit. The trial court therefore concluded that the claims were not time barred. The court of appeals reversed, concluding that the fraud should have been discovered, as a matter of law, more than four years before Plaintiff filed suit because Plaintiff should have discovered the relevant information in the Texas Railroad Commission’s public records. The Supreme Court reversed, holding that Plaintiff’s reasonable diligence in discovering the underlying fraud was a question of fact for the jury. Remanded. View "Hooks v. Samson Lone Star, Ltd. P’ship" on Justia Law

The Office of the Attorney General filed an action against Cornelius Jackson seeking to establish his paternity and to compel him to pay child support. The associate judge issued a temporary order establishing the parent-child relationship and ordering Jackson to pay child support. Additionally, the associate judge denied OAG’s request to prevent disclosure of certain of Jackson’s and the child’s personal information and, finding that no basis existed to show a history of family violence, ordered OAG to remove the family violence indicator from Jackson’s file and OAG’s system. The trial court affirmed and adopted the associate judge’s temporary order. OAG sought mandamus relief. The Supreme Court conditionally granted the writ of mandamus and directed the trial court to vacate its order, holding that the trial court lacked authority to order OAG to remove the indicator from its files. View "In re Office of the Attorney Gen. of Tex." on Justia Law

Farm Bureau County Mutual Insurance Company filed this declaratory judgment action against Cristil Rogers, Farm Bureau’s insured, seeking a declaration that it had no duty to defend or indemnify Rogers in an underlying tort action and requesting court costs and attorney fees. Rogers answered and prayed for recovery of her court costs and attorney fees. The trial court denied Farm Bureau’s motion for summary judgment, concluding that Farm Bureau had a duty to defend Rogers in the tort action. The order did not expressly address the parties’ claims for attorney’s fees. The court of appeals dismissed Farm Bureau’s appeal for lack of jurisdiction, concluding that the order denying Farm Bureau’s motion for summary judgment was not final and appealable because Rogers did not file a cross-motion for summary judgment. The Supreme Court affirmed, holding (1) the fact that Rogers did not file a cross-motion for summary judgment did not preclude the trial court from entering a final judgment; but (2) in the absence of the trial court’s intent with respect to the parties’ claims for attorney’s fees, the order at issue did not dispose of all parties and claims. View "Farm Bureau County Mut. Ins. Co. v. Rogers" on Justia Law

In 1998, Glenn Johnson suffered serious work-related injuries. In separate administrative proceedings, the parties contested the details and amounts of the lifetime workers’ compensation benefits Johnson was entitled to. Johnson and his wife filed the instant suit against his employer’s workers’ compensation insurance provider and related individuals and entities (collectively, Crawford), alleging that Crawford engaged in a plan to delay and deny benefits that the Johnsons were entitled to receive. Crawford filed a plea to the jurisdiction and motion for summary judgment, arguing that the Texas Department of Insurance Division of Workers’ Compensation had exclusive jurisdiction over all of the Johnsons’ claims because they arose out of the workers’ compensation claims-handling process. The trial court dismissed the Johnsons’ claims for breach of the common law duty of good faith and fair dealing and for violations of the Texas Insurance Code but refused to dismiss any of the other claims. The Supreme Court conditionally granted mandamus relief, holding that all of the Johnsons’ claims arose out of Crawford’s investigation, handling, and settling of claims for workers’ compensation benefits, and therefore, the Division had exclusive jurisdiction over the Johnsons’ claims. View "In re Crawford & Co." on Justia Law

This case stemmed from a collision between a tractor-trailer owned by Nabors Well Services, Ltd. and a pickup truck occupied by three family members (the Loeras). During trial, the court admitted evidence that the Loeras were not using seat belts. The jury found Nabors’s driver fifty percent at fault, Nabors ten percent at fault, and the driver of the pickup forty percent at fault. The jury awarded the Loeras approximately $450,000 in damages, but the trial court entered a take-nothing judgment, presumably based on the jury’s answers to two questions regarding the Loeras’ failure to use seat belts. The court of appeals remanded the case for a new trial, concluding that the admission of evidence of nonuse of seat belts was harmful error. While Nabors’ petition for review was pending, the Supreme Court decided Nabors Well Services, Ltd. v. Romero, in which the Court held that relevant evidence of use or nonuse of seat belts is admissible for the purpose of apportioning responsibility in civil lawsuits. The Supreme Court vacated the judgment of the court of appeals and remanded for reconsideration in light of Romero. View "Nabors Well Servs., Ltd. v. Loera" on Justia Law

Petitioner owned and operated a charter bus that collided with a car driven by Respondent. Respondent filed this negligence action against Petitioner seeking damages for the injuries he sustained in the collision. Before trial, Respondent filed a motion for spoliation of evidence requesting that Petitioner be sanctioned because it destroyed a video recording of the accident. The trial court orally ruled that Petitioner had negligently spoliated evidence and ordered the inclusion of a spoliation instruction in the jury charge. The jury found in Respondent’s favor. Petitioner appealed, arguing that the trial court erred in submitting the spoliation instruction. The court of appeals affirmed, concluding that Petitioner waived any complaint it had about the instruction. The Supreme Court reversed, holding (1) Petitioner preserved error by responding to the pretrial motion for sanctions, even while failing to formally object to the instruction’s inclusion in the jury charge until after it was read to the jury; and (2) the trial court committed reversible error by submitting the instruction. Remanded for a new trial. View "Wackenhut Corp. v. Gutierrez" on Justia Law

In this case, the Supreme Court overruled its long-standing rule prohibiting self belt evidence in car accident cases. This ruling was the result of the Legislature’s overhaul of Texas’s system for apportioning fault in negligence cases and the change in law requiring seat belt use. The trial court in the instant case relied on the Court’s precedent in prohibiting seat belt evidence. The court of appeals affirmed the trial court’s judgment solely on the ground that seat belt evidence was properly excluded. The Supreme Court reversed, holding that relevant evidence of use or nonuse of seat belts is admissible for the purpose of apportioning responsibility in civil lawsuits, provided that the plaintiff’s conduct caused or was a cause of his damages. Remanded. View "Nabors Well Servs., Ltd. v. Romero" on Justia Law

A judgment creditor attempted to collect from a partnership after receiving a judgment against the partnership. The partnership proved to be undercapitalized, and its assets could not satisfy the judgment debt. The judgment creditor brought this action seeking a judgment against the individual partners. The trial court granted the partners’ motion for summary judgment. The court of appeals affirmed, concluding that limitations precluded pursuit of the partners’ assets because the limitations period began when the underlying cause of action accrued, and that period had passed. The court of appeals affirmed. The Supreme Court reversed, holding (1) the limitations period against a partner generally does not commence until after final judgment against the partnership is entered; and (2) because this action was brought within that period, limitations did not bar this suit against the partners. View "Am. Star Energy & Minerals Corp. v. Stowers" on Justia Law