Justia Texas Supreme Court Opinion Summaries

Plaintiffs sued Ford Motor Company for injuries they sustained in a roll-over accident. The case was submitted to a jury. After the jury began its deliberations, the parties agreed to settle the case. Ford, however, later refused to pay the settlement amount to Plaintiffs, and Plaintiffs sued for breach of contract. After hearing all of the evidence, the jury found the settlement agreement was invalid because of fraudulent inducement and mutual mistake. The court of appeals reversed the trial court’s take-nothing judgment, concluding that the circumstantial evidence of fraud in the case was legally insufficient. The Supreme Court reversed the court of appeals’ judgment and reinstated the judgment of the trial court, holding that the circumstantial evidence was legally sufficient to support the jury’s verdict. View "Ford Motor Co. v. Castillo" on Justia Law

Respondents sold a collection of insurance companies to Petitioners in an agreement that contained an arbitration clause. Petitioners later invoked arbitration, alleging breach of contract. After Respondents complained about Petitioners’ first and second choice arbitrators the American Arbitration Association (AAA) struck the arbitrators. Petitioners’ third appointee was not challenged, and the arbitration proceeding resulted in an award in Respondents’ favor. When Respondents filed a motion to confirm the award in the trial court, Petitioners renewed their previous objection to the disqualification of their first-choice arbitrator. Ultimately, the court of appeals held that the arbitration panel was properly appointed under the terms of the arbitration agreement and the AAA rules. The Supreme Court reversed, holding (1) because the AAA disqualified Petitioners’ first-choice arbitrator for partiality, the arbitration panel was formed contrary to the express terms of the arbitration agreement; (2) therefore, the arbitration panel exceeded its authority when it resolved the parties’ dispute; and (3) accordingly, the arbitration award must be vacated. View "Americo Life, Inc. v. Myer" on Justia Law

Keystone-Texas Property Holding Corporation owned the Rivercenter Mall and the ground beneath the San Antonio Marriott Riverwalk hotel. Keystone leased the hotel land to Petitioners, who owned and operated the hotel. In 2004, Keystone put the two properties up for sale. After Keystone found a prospective buyer, Petitioners informed Keystone they were interested in buying the land and were not ready to waive their rights under the lease. The deal to sell the properties fell through, and Keystone sued Petitioners for actions Keystone believed scuttled the deal. A jury found for Keystone on all issues and awarded damages for slander of title and tortious interference with a contract. The Supreme Court reversed, holding that there was no evidence Petitioners caused any damages to Keystone. View "HMC Hotel Props. II Ltd. P’ship v. Keystone-Texas Prop. Holding Corp." on Justia Law

Borrower borrowed $696,000 from Lenders. The note was secured by a deed of trust covering real property. Guarantor guaranteed the loan under a guaranty agreement that included a general waiver of defenses. Borrower subsequently defaulted on the loan, and Purchaser purchased the secured property in a nonjudicial foreclosure sale for $487,200. The fair market value of the property was $840,000. Purchaser sued Guarantor to recover the $266,748 balance remaining on the note after applying all credits and the proceeds from the sale. Guarantor argued that under Tex. Prop. Code Ann. 51.003 any deficiency owed should be offset by the difference between the fair market value and the foreclosure price. The trial court granted summary judgment for Guarantor. The court of appeals reversed, holding (1) section 51.003 creates an affirmative defense, and (2) by agreeing to a general waiver of defenses in the guaranty agreement Guarantor waived his right of offset. The Supreme Court affirmed, holding that Guarantor waived his statutory right to an offset. View "Mehrdad v. Interstate 35/Chisam Road, L.P." on Justia Law

Plaintiffs, two groups of cotton farmers, filed suits against the cooperative of which they were members under contract, alleging that they were fraudulently induced to join the cooperative. Plaintiffs’ agreements with the cooperative provided for the arbitration of all disputes under the Federal Arbitration Act (FAA). The cooperative filed a motion to stay the litigation and a motion to compel arbitration. The trial court denied the motions, concluding that the parties’ arbitration agreement was unconscionable. The court of appeals affirmed, reasoning that the agreements were unconscionable because they forced the farmers to “forego substantive rights and remedies afforded by statute.” The Supreme Court reversed, holding that the limitation of statutory remedies was insufficient to defeat arbitration under the FAA. Remanded. View "Venture Cotton Coop. v. Freeman" on Justia Law

The trial court terminated Mother’s and Father’s parental rights to their three children on endangerment grounds and found that termination was in the children’s best interests. Father appealed the judgment. The court of appeals reversed, concluding that there was insufficient evidence to support the endangerment grounds. The Department of Family and Protective Services appealed, arguing that the court of appeals’ factual sufficiency review of the evidence contained several legal flaws. The Supreme Court affirmed, holding that the court of appeals applied the appropriate standard of review, reviewed all the evidence, and explained its insufficiency. View "In re S.M.R." on Justia Law

Plaintiff brought suit in state court against two county sheriff’s department deputies stemming from the officers’ conduct incident to Plaintiff’s arrests. Plaintiff then brought suit in federal court against the county and county sheriff alleging the same tort claims she had made against the officers, based on vicarious liability principles, and alleging violations of her civil rights. In the state court action, the trial court denied the officers’ motion for summary judgment under the Texas Tort Claims Act’s (TTCA) election-of-remedies provision. The Supreme Court reversed and rendered judgment in favor of the officers, holding (1) Plaintiff’s suit on the officers was based on the conduct within the general scope of the officers’ employment and could have been brought under the TTCA against the government, and therefore, Plaintiff’s suit was against the officers in their official capacity only; and (2) because the officers were sued in their official capacities, they were entitled to dismissal under the TTCA’s election-of-remedies provision. View "Alexander v. Walker" on Justia Law

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