Justia Texas Supreme Court Opinion Summaries

Andrea Ruiz was driving a Kia Spectra when she was involved in an automobile accident in which the driver’s-side frontal air bag failed to deploy. Andrea died from dislocated vertebrae in her neck. The Ruiz family filed a products liability action against Kia Motors Corporation and Kia Motors America, Inc. (collectively, “Kia”), and the trial court entered judgment against Kia. The court of appeals affirmed. The Supreme Court reversed and remanded for a new trial, holding (1) the presumption of nonliability in Tex Civ. Prac. & Rem. Code Ann. 82.008 did not apply in this case; (2) the evidence was legally sufficient to support the jury’s design-defect finding; but (3) the trial court erred in admitting irrelevant evidence of other, dissimilar incidents, and the error was harmful. View "Kia Motors Corp. v. Ruiz" on Justia Law

In this oil and gas billing dispute, Plaintiffs sued Defendant for, inter alia, breach of a joint operating agreement. Defendant counterclaimed and prevailed on its counterclaim. The trial court awarded Defendant prejudgment interest, but the court of appeals remanded to recalculate prejudgment interest. On remand, the trial court determined that the record had to be reopened, but rather than obtain the additional evidence, Plaintiff waived its claim for prejudgment interest. The trial court then awarded Defendant postjudgment interest from the date of its original, erroneous judgment. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in determining that new evidence was needed; but (2) because the remand necessitated reopening the record for additional evidence, postjudgment interest must accrue from the final judgment date rather than the original judgment date. Remanded. View "Long v. Castle Tex. Prod. Ltd. P’ship" on Justia Law

Saul Morales was fleeing from the police when one of the police officers left his Ford vehicle, then pursued and apprehended Morales. The officer’s vehicle began rolling backward toward the pair while the officer attempted to handcuff Morales. The vehicle ran over and came to rest on top of Morales, injuring him. Morales sued Ford Motor Company and the car’s seller (collectively, “Ford”), alleging that the vehicle had a design defect. After deposing two of Ford’s expert witnesses, Morales sought to depose a corporate representative of each expert’s employer to expose potential bias. The Supreme Court conditionally granted mandamus relief, holding that on the facts of this case, the Rules of Civil Procedure did not permit such discovery. View "In re Ford Motor Co. & Ken Stoepel Ford, Inc." on Justia Law

Crosstex Energy Services, LP hired Pro Plus, Inc. as the principal contractor to construct a natural gas compression station. Crosstex sued Pro Plus after an explosion occurred at the station, causing $10 million in property damage. The parties entered an agreement to move expert designation dates beyond the limitations period, but after limitations ran, Pro Plus filed a motion to dismiss because Crosstex had not filed a certificate of merit with its original petition as required by Tex. Civ. Prac. & Rem. Code Ann. 150.002. The trial court denied the motion and granted Crosstex an extension to file the certificate. The court of appeals reversed. The Supreme Court affirmed, holding (1) the court of appeals did not err in asserting jurisdiction over Pro Plus’s interlocutory appeal of the extension order; (2) section 150.002’s “good cause” extension is available only when a party filed suit within ten days of the end of the limitations period, and therefore, Crosstex could not claim protection from the good cause extension; and (3) a defendant’s conduct can waive the plaintiff’s certificate of merit requirement, but Pro Plus’s conduct did not constitute waiver. View "Crosstex Energy Servs. L.P. v. Pro Plus, Inc." on Justia Law

Veasna Sok sued Bioderm Skin Care, LLC and Dr. Quan Nguyen after Sok purchased laser hair removal treatments from Bioderm and allegedly received burns and scars on her legs due to too high an intensity setting. When Sok did not serve an expert report within 120 days of filing her original petition, Defendants moved to dismiss Sok’s claim, asserting that it was a health care liability claim under the Texas Medical Liability Act. The trial court denied the motion to dismiss, and the court of appeals affirmed. The Supreme Court reversed and remanded for the trial court to dismiss the claim, holding (1) the rebuttable presumption that Sok’s claim was a Sok care liability claim applied in this case; and (2) Plaintiff failed to rebut this presumption because expert health care testimony was necessary to prove or refute her claim. View "Bioderm Skin Care, LLC v. Sok" on Justia Law

When Tyco Valves & Controls, L.P. decided to close one of its facilities located in Houston, Tyco offered certain employees retention agreements providing that, if the employees remained with the company through the facility’s closure, they would receive severance payments in the event they were not offered comparable employment with Tyco. After Tyco sold one of the production units located in the facility to another company, Plaintiffs, several former employees who had worked in that unit and been denied severance, filed a breach of contract action against Tyco. The trial court ruled in favor of the employees and awarded the severance pay. The court of appeals reversed. The Supreme Court affirmed, holding that the Employee Retirement Income and Security Act of 1974 preempted Plaintiffs’ breach-of-contract claims. View "Arsenio Colorado v. Tyco Valves & Controls, L.P." on Justia Law

Decedent's family (the Kings) sued Toyota and the local Toyota dealership after Decedent lost control of his Toyota, which rolled over several times. The Kings asserted that the Toyota's allegedly defective seat belt system caused Decedent's ejection from the car and his subsequent death. The jury returned a verdict in Toyota's favor, and the trial court signed a corresponding judgment. The Kings moved for a new trial, alleging that Toyota's counsel had violated the trial court's limine rulings. The trial court granted the Kings' motion. Toyota subsequently filed an original proceeding in the Supreme Court. At issue was whether an appellate court may, in an original proceeding, determine whether the reasonably specific and legally sound rationale of the trial court for ordering a new trial was actually true. The Court conditionally granted relief, holding (1) an appellate court may conduct a merits review of the basis for a new trial order after a trial court has set aside a jury verdict, and if the record does not support the trial court's rationale for ordering a new trial, the appellate court may grant mandamus relief; and (2) in this case, the trial court abused its discretion in granting a new trial. View "In re Toyota Motor Sales, U.S.A., Inc." on Justia Law

Claimant suffered a compensable injury to his right ankle in 1991 and developed reflex sympathetic dystrophy in the injured ankle. In 1997, the appeals panel determined Claimant was entitled to Lifetime Income Benefits (LIBs). The workers' compensation carrier for Claimant's employer (Insurer) did not seek judicial review of that decision. More than a decade later, Insurer sought a new contested case hearing on Claimant's continuing eligibility for LIBs. A hearing officer found that Insurer could re-open the previous LIB determination but that Claimant remained entitled to LIBs. The appeals panel affirmed. Both parties sought judicial review. The trial court granted Claimant's motion for summary judgment, concluding that the hearing officer lacked jurisdiction to re-open the previous LIB determination. The court of appeals affirmed. The Supreme Court affirmed, holding that the Legislature does not allow permanent benefit determinations like LIBs to be re-opened.View "Liberty Mut. Ins. Co. v. Adcock" on Justia Law

Plaintiff, a Texas company, sued nonresident Defendants in Texas. Plaintiff asserted claims for (1) trade-secret misappropriation regarding a proposed Texas venture during two meetings Defendants attended in Texas, and (2) tortious interference with Plaintiff's relationship with a California corporation. Defendants specially appeared, claiming specific personal jurisdiction over them was lacking. The trial court granted the special appearances. The court of appeals affirmed, holding (1) the location of the two Texas meetings was "merely random or fortuitous" as to Plaintiff's trade secrets claims, and (2) any alleged tortious interference that might have occurred took place in California. The Supreme Court reversed in part and affirmed in part, holding (1) Defendants' Texas contacts were sufficient to confer specific jurisdiction over Defendants on Plaintiff's trade secrets claim; but (2) the trial court lacked specific personal jurisdiction over Defendants as to Plaintiff's tortious interference claims. Remanded.View "Moncrief Oil Int'l Inc. v. OAO Gazprom" on Justia Law

The Fort Worth Diocese was formed in 1982 and was admitted into union with The Episcopal Church (TEC). The Fort Worth Corporation was formed the next year. After a doctrinal controversy arose within the TEC, the Forth Worth Corporation filed amendments to its articles of incorporation to remove all references to TEC. The Fort Worth Diocese then voted to withdraw from TEC. TEC later filed suit against the Fort Worth Diocese, the Fort Worth Corporation, the former Bishop, and other former TEC members (the Diocese) seeking possession of the property held in the name of the Diocese and the Fort Worth Corporation. The parties disagreed whether the "deference" or "neutral principles of law" methodology should be applied to resolve the property issue. The trial court agreed with TEC that deference principles should apply, and after applying deference principles, granted summary judgment for TEC. The Supreme Court reversed, holding (1) based on the Court's decision in Masterson v. Diocese of Northwest Texas, the trial court erred by granting summary judgment to TEC on the basis of deference principles; and (2) the case must be remanded for further proceedings under neutral principles. Remanded.View "Episcopal Diocese of Fort Worth v. Episcopal Church" on Justia Law