Justia Texas Supreme Court Opinion Summaries

The estate and survivors of Belinda Valdemar sued Health Care Unlimited, Inc. (HCU) and its employee, Edna Gonzalez, after Valdemar died as a result of an automobile accident. Valdemar was a passenger in a vehicle that Gonzalez was driving at the time of the accident. The jury agreed that Gonzalez negligently caused the accident but found that Gonzalez was not acting within the scope of her employment at the time of the accident, and therefore, HCU was not vicariously liable. Valdemar’s survivors filed a motion for a mistrial, alleging that the presiding juror engaged in juror misconduct by communicating with an HCU employee during breaks while the jury was deliberating. The trial court granted the motion. HCU petitioned the court of appeals for mandamus relief, which was denied. The Supreme Court conditionally granted relief, holding that the trial court abused its discretion in granting a new trial, where the facts in this case, without more, did not support a finding that the communications between the juror and the HCU employee probably caused injury. View "In re Health Care Unlimited, Inc. " on Justia Law

Most of the employees at a La Porte unit (“Unit”) of E. I. du Pont de Nemours and Company (“DuPont”) were covered by a collective bargaining agreement (“CBA”). When DuPont announced plans to spin off part of its operations, including the Unit, into a wholly owned subsidiary, DuPont Textiles and Interiors (“DTI”), almost all of the Unit employees moved to DTI, even though the CBA gave the employees the right to transfer to other DuPont jobs. DuPont subsequently sold DTI to Koch Industries, which reduced the former DuPont employees’ compensation and retirement benefits. Several of the former DuPont employees sued DuPont for fraudulently inducing them to terminate their employment and accept employment with DTI by misrepresenting that DTI would not be sold. The Fifth Circuit Court of Appeals certified questions of law to the Texas Supreme Court, which answered by holding (1) at-will employees cannot bring an action against their corporate employer for fraud that is dependent on continued employment; and (2) employees covered under a cancellation-upon-notice CBA that limits the employer’s ability to discharge its employees only for just cause cannot bring Texas fraud claims against their employer based on allegations that the employer fraudulently induced them to terminate their employment. View "Sawyer v. E.I. du Pont de Nemours & Co." on Justia Law

Plaintiffs filed a premises liability suit against Defendant, Whataburger Restaurants LP, for injuries sustained in a fight outside of Defendant’s restaurant. The jury rendered a 10-2 verdict in favor of Defendant, and the trial court entered a take-nothing judgment based on the jury’s verdict. Plaintiffs filed a motion for new trial, asserting that one of the ten majority jurors had committed misconduct when she failed to disclose prior to trial that she had previously been a defendant in a lawsuit. The trial court granted Plaintiffs’ motion for new trial on the ground that Plaintiffs were denied the opportunity to question or strike the juror in light of the missing information. Defendant filed a petition for writ of mandamus in the court of appeals, which was denied. Defendant sought mandamus review in the Supreme Court. The Court conditionally granted the petition, holding that because the record contained no competent evidence that the juror’s nondisclosure resulted in probable injury, and the only competent evidence supported that it did not, the trial court abused its discretion in granting a new trial. View "In re Whataburger Rests. LP" on Justia Law

Plaintiff sued Defendant, which provided laser hair removal services, for negligence after she allegedly suffered burns and scarring on her face and neck while receiving laser hair removal treatments. Defendant filed a motion to dismiss because Plaintiff had not served an expert report as required by the Medical Liability Act for health care liability claims. The trial court denied the motion to dismiss, and the court of appeals affirmed. The Supreme Court reversed, holding that Plaintiff did not rebut the presumption that her claim for improper laser hair removal was a health care liability claim, and therefore, Plaintiff’s failure to serve an expert report precluded her suit. View "Rio Grande Valley Vein Clinic, P.A. v. Guerrero" on Justia Law

Respondents filed claims against Petitioners relating to certain oil and gas ventures. At issue in this case was Respondents’ assignment claim, which an involved an agreement between Respondents and Petitioners for Respondents to pay a portion of drilling and operating costs in exchange for an assignment of a partial working interest in producing wells. After a bench trial, the trial court largely ruled for Respondents and awarded them $35,000 in attorney’s fees. The Supreme Court modified Respondents’ recovery on appeal and remanded for the trial court to redetermine the attorney’s fee award. On remand, the trial court awarded Respondents $30,000 in attorney’s fees. The Supreme Court reversed, holding that no legally sufficient evidence supported the amount of the attorney’s fee award because Respondents offered no evidence of the time expended on particular tasks as required via the lodestar method. Remanded. View "Long v. Griffin" on Justia Law

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