Justia Texas Supreme Court Opinion Summaries

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

An owner contracted with an Architect to prepare plans and specifications for the construction of a light rail. A General Contractor was awarded the contract to construct the project. The Architect and General Contractor had no contract with each other. Because the Architect’s plans were full of errors, the General Contractor lost nearly $14 million on the project. The General Contractor filed a tort suit against the Architect, alleging negligent misrepresentation. The trial court rendered judgment for the General Contractor for $2.25 million plus interest. The Architect appealed, arguing that the economic loss rule barred the General Contractor’s claim. The Supreme Court reversed, holding that the economic loss rule applied in this case to preclude the General Contractor from recovering delay damages from the Architect. View "LAN/STV v. Martin K. Eby Constr. Co., Inc." on Justia Law

Plaintiff, a patron of the Graham Central Station nightclub, was assaulted by other patrons of the club. Plaintiff sued Graham Central Station, Inc. (GCS), the nightclub’s purported owner, alleging that GCS failed to provide adequate security to protect Plaintiff. The trial court rendered judgment for Plaintiff and awarded him $450,000 for pain and suffering and mental anguish. GCS appealed, arguing that Plaintiff sued the wrong party and that the evidence was insufficient to support the damages award. The court of appeals reduced Plaintiff’s damages to $249,000 and otherwise affirmed. The Supreme Court reversed the court of appeals’ judgment and rendered judgment in GCS’s favor, holding that the evidence supporting a finding that GCS owned the nightclub was legally insufficient, and therefore, there was insufficient evidence that GCS owed a duty to Plaintiff. View "Graham Cent. Station, Inc. v. Pena" on Justia Law

A mineral lessee operated two wells on two contiguous tracts of land. When one of the wells stopped producing, the lessee pooled parts of the two mineral leases. Landowners subsequently bought a tract of land that included the road the lessee used to access the producing well. The road was across the surface of the lease without production. After traffic on the road increased, the landowners filed suit against the lessee, claiming that the lessee had no legal right to use the surface of their tract of land to produce minerals from the operating well. The trial court determined that the lessee did not have the right to use the road to access the producing lease and granted declaratory and injunctive relief. The Supreme Court reversed, holding (1) once pooling occurred, the pooled parts of the two contiguous tracts no longer maintained separate identities insofar as where production from the pooled interests was located; and (2) therefore, the lessee had the right to use the road to access the pooled part of the tract of land containing the producing well. View "Key Operating & Equip., Inc. v. Hegar" on Justia Law