Justia Texas Supreme Court Opinion Summaries

At issue in this case was the Texas-resident exception to the forum non conveniens statute, which allows “plaintiffs” who are legal residents of Texas to bring a case in a Texas forum even if forum non conveniens would otherwise favor dismissal. Here an estate was sued in Texas regarding a Mexican decedent’s alleged responsibility for a car accident that occurred in Mexico. The estate in turn filed a third-party claim against Ford Motor Company. Wrongful-death beneficiaries, three of whom were legal residents of Texas, intervened in the lawsuit and also filed claims against Ford. Ford moved to dismiss under forum non conveniens, and the trial court denied the motion. Ford then moved for mandamus relief. The court of appeals denied relief, reasoning that, because at least one of the beneficiaries was a legal resident of Texas, the wrongful-death beneficiaries were “plaintiffs” that could take advantage of the Texas-resident exception to forum non conveniens. The Supreme Court denied mandamus relief, holding that the wrongful-death beneficiaries are distinct plaintiffs that can rely on the Texas-resident exception. View "In re Ford Motor Co." on Justia Law

At issue in this case was whether the statutory requirement that a plaintiff in any action for damages arising out of the provision of professional services by a licensed or registered professional file a supporting expert affidavit with the complaint applies to a defendant or third-party defendant who files a third-party claim or cross-claim against a licensed or registered professional. In the underlying complaint, the court of appeals concluded that chapter 150 of the Texas Civil Practice and Remedies Code does not require third-party plaintiffs or cross-claimants to file a certificate of merit. The Supreme Court affirmed, holding that the certificate-of-merit requirement in chapter 150 does not apply to a defendant or third-party defendant who asserts claims against a licensed or registered professional because they are not the “plaintiff” in such cases. View "Jaster v. Comet II Constr., Inc." on Justia Law

In this case, the Supreme Court articulated with greater clarity the standards governing whether an act of spoliation has occurred and the limits of a trial court’s discretion to impose certain remedies upon a finding of spoliation. In the underlying slip-and-fall premises-liability case, the defendant-premises owner retained a portion of surveillance video footage of the plaintiff’s fall but allowed additional footage to be automatically erased. The trial court submitted a spoliation instruction to the jury and allowed the jury to decide whether spoliation occurred. The jury rendered a verdict in favor of the plaintiff. The Supreme Court reversed, holding that the trial court abused its discretion in imposing the severe sanction of a spoliation instruction. Remanded for a new trial. View "Brookshire Bros., Ltd. v. Aldridge" on Justia Law

A family from Mexico hired Jose Marciel, a “coyote,” to transport them to Houston or New Orleans. Marciel collected the family at a house in Texas, and, before dawn, arrived at the private Jones Ranch. An employee of the ranch operator stopped Maciel to ask why he had entered the property, after which Maciel fled at high speed. The vehicle rolled over, killing the family. Respondents, the deceased mother’s parents, sued the ranch’s operators and an employee (collectively, Petitioners), alleging wrongful death claims, including negligence and gross negligence. The trial court granted summary judgment for Petitioners. The court of appeals reversed in part. The Supreme Court reversed in part and affirmed in part, holding (1) the trial court erred in granting a traditional summary judgment based on the common law unlawful acts doctrine because the statutory comparative responsibility scheme abrogated this doctrine; (2) a land occupier owes only a duty to avoid injuring a trespasser wilfully, wantonly, or through gross negligence, and therefore, Respondents’ claim for simple negligence must fail as a matter of law; and (3) as to gross negligence, the trial court properly granted a no-evidence summary judgment motion because Respondents failed to raise a genuine issue of material fact. View "Boerjan v. Rodriguez" on Justia Law

Randall Hughes was an employee and a minority shareholder of Cardiac Perfusion Services, Inc. (CPS). After Hughes’s employment terminated, CPS and Michael Joubran filed an action against Hughes and also requested declaratory relief. Hughes filed counterclaims for breach of fiduciary duty against Joubran, alleging that Joubran engaged in oppressive conduct toward him. After a jury trial, the trial court ordered Joubran and CPS to buy out Hughes’s shares based on its determination that Joubran engaged in “oppressive conduct” to the rights of Hughes. The court of appeals affirmed. The Supreme Court reversed in part and affirmed in part, holding that there is no common-law cause of action for shareholder oppression, and the only statutory remedy for “oppressive” actions is a rehabilitative receivership. Remanded. View "Cardiac Perfusion Servs., Inc. v. Joubran" on Justia Law

Petitioners owned the royalty interests under two oil and gas leases. The leases were later pooled to form the Cogdell Canyon Reef Unit (CCRU). Since the CCRU was formed, a method of enhanced oil recovery began to be used by injecting carbon dixoide into the reservoir to sweep the oil to the production wells. With this method, the carbon dioxide returns to the surface entrained in casinghead gas, which is gas produced with the oil. At issue in this case was whether the royalty due on the gasinghead gas under the parties’ agreements must be determined as if the injected carbon dioxide were not present and whether the royalty owners were required to share with the working interest the expense of removing the carbon dioxide from the gas. The Supreme Court concluded that, under the parties’ agreements the royalty owners must share in the cost of carbon dioxide removal and were not entitled to a royalty based on the carbon dioxide’s value when it is produced with the casinghead gas. View "French v. Occidental Permian Ltd." on Justia Law

The Texas Department of Family and Protective Services (DFPS) removed a child from the custody of his Mother. After DFPS decided not to seek termination of Mother’s rights, the child’s Foster Parents filed suit, seeking appointment as the child’s joint managing conservators. After a jury trial, the trial court appointed the Foster Parents as the child’s sole managing conservators. The court of appeals reversed and awarded Mother managing conservatorship, concluding that the evidence was legally insufficient to support the jury’s finding that Mother’s appointment as the child’s conservator would significantly impair the child’s physical health or emotional development. The Supreme Court reversed, holding that because the court of appeals did not reach the question of whether the evidence was factually - as opposed to legally - sufficient to support the verdict, the case must be remanded for factual sufficiency review. View "Danet v. Bhan" on Justia Law

Jimmy Carty died in an accident during his employment for the state. The workers’ compensation carrier for state employees (carrier) began paying death benefits to Christy, Jimmy’s wife, and the couple’s three minor children. Christy, individually, as representative of her deceased husband’s estate, and as next friend of the couple’s children, brought suit against two defendants. The Cartys settled with the defendants. The district court subsequently calculated the carrier's reimbursement and apportioned the remainder of the settlement funds among Christy and the children “in the same ratio as they received death benefits.” The carrier appealed, challenging the apportionment. The court of appeals certified to the Supreme Court the question of “how a net recovery in excess of the amount of benefits paid by the workers’ compensation carrier should be apportioned among beneficiaries when multiple beneficiaries recover from a third-party tortfeasor.” The Supreme Court answered that when multiple beneficiaries recover compensation benefits through the same covered employee, the workers’ compensation carrier’s right to a third-party settlement is determined by treating the recovery as a single, collective recovery rather than separate recoveries by each beneficiary. View "State Office of Risk Mgmt. v. Carty" on Justia Law

A minority shareholder (Plaintiff) filed suit against a closely held corporation and the corporation’s board of directors, alleging that the directors engaged in oppressive conduct and breached their fiduciary duties by refusing to buy Plaintiff’s shares for fair value or meet with prospective buyers. The jury found in Plaintiff’s favor on essentially all of her claims. The trial court rendered judgment on the jury’s verdict and ordered the corporation to purchase Plaintiff’s shares for $7.3 million. The court of appeals upheld the buy-out order, concluding that the directors’ refusal to meet with Plaintiff’s prospective purchasers constituted oppressive conduct as a matter of law. The Supreme Court reversed, holding (1) the directors’ conduct was not “oppressive” under the relevant statute; (2) the statute does not authorize courts to order a corporation to buy out a minority shareholder’s interests; and (3) there is no common-law cause of action for “minority shareholder oppression.” Remanded for consideration of Plaintiff’s breach of fiduciary duty claim. View "Ritchie v. Rupe" on Justia Law

A corporation invited guests to a business retreat at the corporation’s expense at a lodge near the Gulf of Mexico. The lodge provided the guests with bay fishing from small boats. The corporation provided alcoholic beverages on the boats at the guests’ request. After one guest spent some time on the boat, returned to the lodge, and left to drive home, the guest struck a motorcycle ridden by the plaintiffs, who were severely injured. The plaintiffs sued the corporation, alleging that it negligently allowed the guest to drink excessively. Because Texas law does not recognize such social host liability, the plaintiffs asserted that federal maritime law applied in this case because, before the accident, the guest became intoxicated while on the fishing boat. The court of appeals concluded that maritime law applied. The Supreme Court reversed, holding that, under the tests set forth by the U.S. Supreme Court in Jerome B. Grubart, Inc. v. Great Lakes Dredge & Dock Co., the action did not fall within admiralty jurisdiction. View "Schlumberger Tech. Corp. v. Arthey" on Justia Law