Justia Texas Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals in this personal injury case, holding that the court of appeals erred in concluding that the trial court abused its discretion in admitting Valerie McElwrath's lay testimony and in determining that the admission of her testimony probably caused the rendition of an improper judgment.Reuben Hitchcock fell to the ground while he was standing in the front-end loader of a tractor and was trimming the tree of his neighbor, Defendant. Later that night, Hitchcock called for an ambulance and was hospitalized. He died one month later. Plaintiff, Hitchcock's sister, brought this action alleging that Defendant was negligent and grossly negligent for failing to take certain actions. The jury rendered a verdict for Defendant, and the trial court rendered a take-nothing judgment on the jury's verdict. The court of appeals reversed, holding that the trial court's error in admitting the testimony of McElwrath, Hitchcock's neighbor, was prejudicial. The Supreme Court reversed, holding that the admission of McElwrath's testimony, even if erroneous, did not constitute harmful, reversible error. View "Jackson v. Takara" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the order of the trial court dismissing Duncan House Charitable Corporation's application for a charitable organization exemption, holding that the court of appeals erred in concluding that Duncan's failure to timely apply for later exemption precluded it from receiving that exemption even if it ultimately qualified for an earlier exemption.For the 2017 tax year, Duncan applied for a charitable tax exemption covering its fifty percent ownership interest in a Houston historic home. The appraisal district denied the exemption, and the review board denied Duncan's ensuing protest. Duncan filed for judicial review. Thereafter, although Duncan House never applied for the charitable exemption for the 2018 tax year, it protested the district's 2018 appraisal on the grounds that the district court to apply the charitable exemption. The review board denied the protest. Duncan then amended its trial court petition to challenge the denial of the 2018 exemption. The trial court dismissed the 2018 claim for want of jurisdiction, and the court of appeals affirmed. The Supreme Court reversed, holding that the court of appeals erred in holding that Duncan's failure to timely apply for the 2018 exemption precluded it from receiving that exemption even if it ultimately qualified for the 2017 exemption. View "Duncan House Charitable Corp. v. Harris County Appraisal District" on Justia Law

The Supreme Court vacated the judgment of the court of appeals in this case involving the question of deed construction within the oil and gas context as to whether a royalty interest was fixed or floating, holding that further proceedings were required to evaluate this case in light of the framework articulated in Van Dyke v. Navigator Group, 668 S.W.3d 353 (Tex. 2023).The 1956 deed at issue expressly reserved an undivided 3/32's interest "(same being three-fourths (3/4's) of the usual one-eighth (1/8th) royalty)" in the oil, gas, and other minerals. The question before the Supreme Court was whether the reservation was a floating 3/4 interest of the royalty rather than a fixed 3/32 interest. The court of appeals concluded that the reservation was a floating 3/4 interest. Because the court of appeals' decision preceded Van Dyke, the Court's most recent double-fraction case, the Supreme Court granting the petition for review and vacated the lower court's decision, holding that this case must be remanded this case for further proceedings in light of Van Dyke. View "Thomson v. Hoffman" on Justia Law

The Supreme Court reversed the judgment of the court of appeals in this case concerning whether Apache Corporation breached its purchase-and-sale agreements (PSAs) with Sellers, holding the court of appeals erred by failing to apply the default common-law rule of contractual construction to the parties' dispute and incorrectly construed other contractual provisions at issue.In the PSAs at issue, Sellers sold seventy-five percent of their working interests in 109 oil-and-gas leases to Apache. The trial court rendered final judgment for Apache on the grounds that Sellers had no evidence of damages and could not prevail on their claims. The court of appeals reversed in part. At issue was whether the default rule for treating contracts that use the words "from" or "after" a specified date to measure a length of time should be applied in this case. The Supreme Court reversed the judgment of the court of appeals as to the issues that the parties presented for review, holding that the parties' agreement in this case implicated the default rule without displacing it. View "Apache Corp. v. Apollo Exploration, LLC" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the decision of the trial court appeals denying the Texas Tech University School of Medicine's combined plea to the jurisdiction and summary judgment motion in the underlying unlawful discrimination action, holding that morbid obesity does not qualify as an impairment under the Texas Commission on Human Rights Act (TCHRA) without evidence that it is caused by an underlying physiological disorder or condition.After Plaintiff was dismissed from Texas Tech's medical residency program she brought this complaint alleging that the University dismissed her because of her morbid obesity, which she argued constituted unlawful discrimination under the TCHRA. The University filed a combined plea to the jurisdiction and summary judgment motion, arguing that it was protected under sovereign immunity. The trial court denied the plea and motion, and the court of appeals affirmed. The Supreme Court reversed, holding (1) morbid obesity qualifies as an impairment under the Labor Code only when caused by a physiological disorder or condition; and (2) Plaintiff could not establish that the University regarded her as having an impairment, and Plaintiff failed to show a disability as defined in the Labor Code. View "Tex. Tech University Health Sciences Center - El Paso v. Niehay" on Justia Law

The Supreme Court vacated the judgment of the court of appeals affirming the trial court's judgment issuing in July 2021 a temporary restraining order prohibiting enforcement of executive order GA-38, holding that this case is remanded for further proceedings consistent with this Court's opinion in Abbott v. Harris County, 22-0124, which concerned the scope and constitutionality of the Governor's authority under the Disaster Act to prohibit local governments from imposing mask requirements.The City of San Antonio and Bexar County jointly filed this lawsuit challenging GA-38, which prohibited local officials from requiring masks in response to the coronavirus epidemic. The district court issued a temporary restraining order prohibiting enforcement of the executive order and then temporarily enjoined the Governor and others from enforcing GA-38 to the extent that such a requirement would interfere with the local official's authority to require masks in government-owed buildings and schools. The court of appeals affirmed the temporary injunction. In light of this Court's decision in Abbott v. Harris County, the Supreme Court vacated the judgment below, holding that remand was required. View "Abbott v. City of San Antonio" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the judgment of the trial court on the jury's verdict finding both the railroad and the woman killed in this case negligent and equally responsible for causing the accident that killed Petitioners' mother, holding that a new trial was required.Ladonna Sue Rigsby was hit by a KC Southern train as she drove across a railroad track. Petitioners brought a wrongful death action against the Kansas City Southern Railway Company (KC Southern) alleging that KC Southern negligently maintained a humped railroad crossing that lacked a yield sign. The jury found both Rigsby and KC Southern negligently caused the accident and assigned fifty percent of the responsibility to each. The trial court entered a final judgment based on the verdict. The court of appeals reversed because it could not determine whether the jury rested its liability determination on Petitioners' humped crossing theory, which should not have been submitted to the jury, or Petitioners' missing yield sign theory, which was properly submitted. The Supreme Court affirmed the ultimate conclusion that a new trial was required, holding (1) federal law did not preempt the humped-crossing claim; and (2) no evidence supported the jury's finding that the absence of the yield sign caused the accident. View "Horton v. Kansas City Southern Railway Co." on Justia Law

The Supreme Court reversed the decision of the court of appeals that all of the documents underlying an external investigation into allegations of undue influence in a public university's admissions process were protected by the attorney-client privilege and were thus exempt from disclosure under the Texas Public Information Act, holding that the university's attorney-client privilege as to specific documents was waived.Specifically, the Supreme Court held (1) the investigator acted as a lawyer's representative in conducting the investigation; (2) the subject documents fell within the attorney-client privilege; (3) the university did not waive the privilege by disclosing to the investigator some of the documents; and (4) the publication of the investigator's final report waived the university's attorney-client privilege as to documents that the final report directly quoted from or otherwise disclosed a significant part of. View "University of Tex. System v. Franklin Center for Gov't & Public Integrity" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the dismissal of the underlying cause of action and rendering judgment dismissing the claim, holding that the cause of action was a health care liability claim because it met the applicable factors articulated in Ross v. St. Luke's Episcopal Hospital, 462 S.W.3d 496 (Tex. 2015).Plaintiff sued Defendant for negligence, negligent hiring, and premises liability. Defendant moved to dismiss the case, alleging that it was a health care provider under the Texas Medical Liability Act (Act), Tex. Civ. Prac. & Rem. Code 74.001-74.507 and that Plaintiff failed timely to serve an expert report. Plaintiff amended her petition so that only the premises liability claim remained. The trial court dismissed the claim. An en banc court of appeals reversed, concluding that no expert report was needed because Plaintiff's claim was not a health care liability claim. The Supreme Court reversed, holding that Plaintiff's cause of action constituted a health care liability claim under Ross, and therefore, the TMLA's expert-report requirement applied. View "Collin Creek Assisted Living Center, Inc. v. Faber" on Justia Law

The Supreme Court denied Petitioner's petition for a writ of mandamus in this original proceeding involving more than 2,000 cases brought by more than 7,000 plaintiffs represented by more than fifty law firms consolidated in an multidistrict litigation (MDL) court, holding that Plaintiffs did not sufficiently plead their claims.This proceeding arose from explosions occurring in the TPC petrochemical processing plant in Port Neches, resulting in the release of toxic chemicals, extensive personal injury, and property damages. At issue before the Supreme Court was whether Plaintiffs sufficiently pleaded claims that investors in the plant owner were directly liable for damages. The Supreme Court denied mandamus relief, holding that Plaintiffs' petition made no factual allegations to show a cause of action with a basis in law against the investors for TPC's conduct. View "In re First Reserve Management, L.P." on Justia Law