Justia Texas Supreme Court Opinion Summaries

Relators filed suit in Harris County for breach of contract and wrongful foreclosure against a Bank. The parties reached a settlement memorialized in a Rule 11 agreement. The trial court later dismissed all claims but did not incorporate the entire Rule 11 agreement. When the parties disagreed on the terms of the settlement, the Bank foreclosed on the property. Relators then filed suit in Bexar County for wrongful foreclosure. Eleven months after the Harris County lawsuit had been dismissed, Bank filed a motion to enforce the settlement agreement. Relator responded that the trial court’s plenary power expired thirty days after signing the dismissal order, and therefore, the trial court lacked jurisdiction to enforce the Rule 11 agreement. The Harris County subsequently granted the Bank’s motion to enforce the Rule 11 agreement. The Supreme Court conditionally granted Relators’ petition for writ of mandamus and directed the trial court to vacate its order granting the Bank’s motion to enforce the settlement agreement, holding that because the trial court’s plenary power had expired, the court lacked jurisdiction to enforce the agreement. View "In re Vaishangi, Inc." on Justia Law

Shayn Proler, a firefighter with the Houston fire department, filed an administrative grievance seeking reassignment to a fire suppression unit under the terms of a collective bargaining agreement. After a hearing, Proler was reassigned to fire suppression. The City appealed, and Proler counterclaimed for disability discrimination. The trial court granted Proler’s plea to the jurisdiction. After a trial, the trial court entered judgment in favor of Proler on his disability claim. The court of appeals (1) reversed the order granting Proler’s plea to the jurisdiction insofar as the City claimed the hearing examiner exceeded his jurisdiction by awarding overtime compensation and insofar as the City requested declaratory judgment relief on this issue; and (2) affirmed the trial court’s judgment awarding injunctive relief and attorney fees to Proler on his disability discrimination claim. The Supreme Court (1) affirmed the court of appeals’ judgment reversing the order granting Proler’s plea to the jurisdiction; and (2) reversed the court of appeals’ judgment insofar as it affirmed the trial court’s judgment granting injunctive relief and attorney fees to Proler on his disability discrimination claim, as there was no evidence Proler was discriminated against on account of a disability. View "City of Houston v. Proler" on Justia Law

Russell Gordon was stopped by City of Watauga police officers and arrested. Gordon subsequently sued the City for injuries to his wrists caused by the officers' use of handcuffs. The City filed a plea to the jurisdiction, asserting that it was immune from suit under the intentional-tort exception to the Tort Claims Act’s governmental immunity waiver. The Act waives sovereign immunity for certain negligent conduct but does not waive immunity for claims arising out of intentional torts, such as battery. The court of appeals affirmed, concluding that the underlying claim was for negligence, and therefore, the City was not entitled to immunity. The Supreme Court reversed and dismissed the case, holding that the underlying claim was for battery, not negligence, and the City’s governmental immunity had not been waived for this intentional tort. View "City of Watauga v. Gordon" on Justia Law

After Plaintiff purchased a used yacht, the yacht’s starboard engine failed beyond repair. Plaintiff sued Defendant-manufacturer, alleging several causes of action, including breach of the implied warranty of merchantability. The jury found Defendant liable only on the implied warranty claim. The trial court granted Defendant’s motion for judgment notwithstanding the verdict because Plaintiff was a subsequent purchaser of the used yacht and because Defendant disclaimed any implied warranty at the time of the first sale. The court of appeals reversed, holding that someone who knowingly buys used goods may still rely on an implied warranty from the manufacturer to the original buyer since the warranty passes with the goods. The Supreme Court affirmed, holding (1) Defendant could not rely on its purported express disclaimer of implied warranties issued at the first sale because it did not properly raise that defense in the trial court; (2) an implied warranty of merchantability, unless properly disclaimed, passes to subsequent buyers; and (3) therefore, Plaintiff was entitled to recover on his implied-warranty claim. View "MAN Engines & Components, Inc. v. Shows" on Justia Law

Petitioner filed an action in state court against Respondent, a county sheriff’s deputy, arising from an incident in which Petitioner was arrested at her home. Petitioner subsequently filed an action in federal court arising out of the same incident against the county and the former county sheriff. The two cases were consolidated in federal court. The federal court dismissed the federal claims against the county and the sheriff and then remanded the tort claims against Respondent. The trial court denied Respondent's motion for summary judgment. The court of appeals reversed, concluding that Petitioner’s suit against the county in federal court entitled Respondent to dismissal under Tex. Civ. Prac. & Rem. Code 101.106(a). The Supreme Court affirmed but for different reasons, holding that Petitioner’s claims against Respondent should have been dismissed under subsection (f) of the Texas Tort Claims Act’s election-of-remedies provision. View "Stinson v. Fontenot" on Justia Law

Petitioners and Respondent entered into an agreement. The parties later disputed whether their agreement required Petitioners to indemnify Respondent for breaching certain representations and warranties in the agreement. The parties proceeded to arbitration, and the arbitrators selected Respondent’s $125 million settlement award. Petitioners moved to vacate the award, asserting that one of the arbitrators was neither impartial nor free from bias. After a hearing, the trial court granted Petitioners’ motion, concluding that the arbitrator did not disclose information that might yield a reasonable impression that the arbitrator was not impartial. The court of appeals reversed, concluding that Petitioners waived their evident partiality claim by failing to object or inquire further when the disclosures occurred. The Supreme Court reversed the court of appeals’ judgment and reinstated the trial court’s order vacating the award and requiring a new arbitration, holding (1) the arbitrator’s failure to disclose the information that might yield a reasonable impression of the arbitrator’s partiality to an objective observer constituted evident partiality; and (2) Petitioners did not waive their partiality challenge. View "Tenaska Energy, LLC v. Ponderosa Pine Energy, LLC" on Justia Law

Two Patients were injured in a car accident with Third-Party. Patients were treated at Hospital, and to secure payment, Hospital filed hospital liens under the Hospital Lien Statute. Patients settled with Third-Party and released their claims against him. Third-party’s Insurer made the settlement checks jointly payable to Patients and Hospital. Patients deposited the checks without Hospital’s endorsement, and Hospital was never reimbursed for the treatment costs. Hospital sued Insurer to enforce its hospital liens, but Insurer refused payment, contending that it met its obligation to pay Hospital under the Hospital Lien Statute by making the checks payable to Hospital as a copayee. The trial court granted summary judgment for Insurer, and the court of appeals affirmed. The Supreme Court reversed, holding (1) Hospital’s charges were not “paid” under the Hospital Lien Statute and Uniform Commercial Code; and (2) Hospital’s liens on Patients’ causes of action remained intact. View "McAllen Hosps., LP v. State Farm County Mut. Ins. Co." on Justia Law

The Gobellans retained Law Firm to defend them and bring suit. Associate was assigned to the case. Associate later left Law Firm and took several clients, including Gobellans, with him. Law Firm sued Associate over client contingency fees, and later settled. Law Firm also sued Gobellans, and moved to compel the dispute to arbitration pursuant to an arbitration clause in the contingency fee agreement between Law Firm and Gobellans. The trial court and court of appeals denied Law Firm’s motion to compel arbitration, concluding that because Law Firm had litigated the fee issue with Associate, it waived its right to arbitrate claims stemming from its fee agreement with Gobellans. The Supreme Court reversed, holding (1) because Law Firm’s litigation conduct involved suing Associate, with whom it had no arbitration agreement, and filing limited pleadings against Gobellans, the conduct did not substantially invoke the litigation process against Gobellans or prejudice them; and (2) thus, Law Firm did not waive its right to arbitrate its dispute with Gobellans. View "Hodges, LLP v. Gobellan" on Justia Law

In 2008, the Texas Department of Family and Protective Services (DFPS) filed suit to terminate Father’s parental rights to his two children. Two trials resulted in the termination of Father’s parental rights. In both cases, the court of appeals reversed and remanded for a new trial on the grounds that there was factually insufficient evidence of endangerment. DFPS and intervenors filed motions for en banc reconsideration. The court of appeals granted the motion and affirmed the termination of Father’s parental rights, finding the evidence of endangerment factually sufficient to support termination. The Supreme Court affirmed, holding that the court of appeals, in affirming the termination, adhered to the proper standard for conducting a factual sufficiency review. View "In re A.B." on Justia Law

Plaintiffs, the recipients of a home equity loan, reached two loan modification agreements with Defendant, which reduced the interest rate and payments. Plaintiffs subsequently brought this class action against Defendant in the United States District Court, alleging that the loan modifications violated Tex. Const. art. XVI, 50, which sets forth requirements for a new home equity loan. The district court dismissed the case for failure to state a cause of action. On appeal, the Fifth Circuit Court of Appeals asked the Supreme Court whether the requirements of Article XVI, Section 50 apply to the type of loan restructuring in this case. The Supreme Court answered that, as long as the original note is not satisfied and replaced, and there is no additional extension of credit, the Constitution does not prohibit the restructuring of a home equity loan that already meets its requirements in order to avoid foreclosure. View "Sims v. Carrington Mortgage Servs., LLC" on Justia Law