Justia Texas Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals reversing the orders of the trial court granting TotalEnergies E&P USA, Inc.'s motion to stay arbitration before the American Arbitration Association (AAA) and denying MP Gulf of Mexico, LLC's motion to compel that arbitration, holding that the parties' contracts required them to resolve their controversies through arbitration.In the underlying dispute involving oil and gas leases Total E&P filed this suit seeking a declaratory construing the parties' cost sharing agreement. Thereafter, MP Gulf initiated an arbitration proceeding asserting that Total E&P breached the agreement. At issue was whether the parties clearly and unmistakably delegated arbitrability issues to the arbitrator by agreeing to arbitrate their controversies in accordance with the AAA Commercial Rules. The trial court granted Total E&P's motion to stay the AAA arbitration and denied MP Gulf's motion to compel that arbitration. The court of appeals reversed and compelled AAA arbitration. The Supreme Court reversed, holding that the parties clearly and unmistakably delegated to the AAA arbitrator the decision of whether the parties' controversy must be resolved by arbitration. View "TotalEnergies E&P USA, Inc. v. MP Gulf of Mexico, LLC" on Justia Law

In this divorce proceeding, the Supreme Court reversed in part the judgment of the trial court granting Father the exclusive right to determine the primary residence of the couple's four children, holding that the trial court erred in failing to conduct an interview of the parties' thirteen-year-old daughter, M.N., and the error was harmful.Under Tex. Fam. Code 153.009(a) parents in a divorce or custody proceeding may request either an interview of the children by the judge or a jury trial but not both. Mother demanded a jury trial but later withdrew her demand to take advance of section 153.009(a)'s mandate that the trial court interview M.N. The court, however, declined to conduct the interview on the ground that Mother had not filed a written motion. In the final divorce decree the parties were appointed joint managing conservators of the children and Father was granted the right to determined the children's primary residence. The court of appeals affirmed. The Supreme Court reversed, holding (1) the trial court erred by declining to undertake its mandatory obligation to interview M.N.; and (2) the error was not harmless because it resulted in the loss of a jury trial on disputed fact questions. View "In re J.N." on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the order of the trial court finding that Mother failed to comply with her service plan and that termination of Mother's rights was in her children's best interest, holding that the trial court's findings were supported by legally sufficient evidence.Mother's parental rights were terminated pursuant to Tex. Fam. Code 161.001(b)(1)(O), under which termination may be ordered if the parent as failed to comply with a court-ordered service plan "as a result of the child's removal from the parent...for the abuse or neglect of the child." The Supreme Court affirmed, holding that the evidence was sufficient to support the trial court's findings that Mother's acts and omissions, which rendered her an unfit parent, were within the statutory definition of "abuse or neglect." View "In re A.A." on Justia Law

The Supreme Court affirmed the judgment of the court of appeals concluding that governmental immunity does not protect a city against a breach of contract claim because the city was acting in its proprietary capacity when it entered into the contract, holding that the court of appeals did not err.In this dispute involving an "Economic Development Incentives Grant Agreement" under Tex. Loc. Gov't Code 373.002(b) Plaintiff alleged that the City of League City breached its agreement to reimburse Plaintiff for certain fees and costs in connection with Plaintiff's construction of a restaurant facility in the City. The City filed a plea to the jurisdiction arguing that governmental immunity barred the claim. The trial court denied the plea. The court of appeals affirmed, concluding that governmental immunity did not apply to the claim. The Supreme Court affirmed, holding that the court of appeals correctly determined that the City engaged in a proprietary function when it entered into the agreement with Plaintiff. View "City of League City v. Jimmy Changas, Inc." on Justia Law

In this premises liability action, the Supreme Court held that the City of Austin had discretion not to implement its policy regarding the maintenance of a permitted sidewalk cafe, and therefore, Appellant failed to plead a claim against the City for which the City's immunity was waived.An agreement between the City and the permit-holder restaurant in this dispute delegated maintenance responsibilities to the restaurant but did not include terms requiring the City to ensure that the restaurant comply with those responsibilities. Plaintiff sued both the restaurant and the City for premises liability. The City filed an amended plea to the jurisdiction, which the trial court denied. The court of appeals affirmed as relevant to this appeal, ruling that the City's immunity was waived as to the claims relating to the City's alleged negligent implementation of its policy regarding the premises' maintenance because the City had a legal duty to ensure the restaurant fulfilled its maintenance obligations. The Supreme Court reversed, holding that the City had discretion to enforce or monitor the restaurant's compliance but was not required to do so, and therefore, dismissal was appropriate. View "City of Austin v. Quinlan" on Justia Law

The Supreme Court reversed the judgment of the court of appeals in this employment discrimination suit ruling that an arbitration agreement was unconscionable and affirming the order of the trial court denying the employer's motion to compel arbitration, holding that the court of appeals erred in ruling that the evidence supported the trial court's finding that the arbitration agreement was unconscionable.After Petitioner terminated Respondent's employment Respondent sued for race discrimination and retaliation under federal and state law. Petitioner moved to compel arbitration based on the arbitration agreement signed by Respondent when he was hired. Respondent opposed the motion, arguing that the agreement was unconscionable. The trial court denied the motion to compel, and the court of appeals affirmed. The Supreme Court reversed, holding that there was insufficient evidence to prove that the agreement was unconscionable. View "Houston AN USA, LLC v. Shattenkirk" on Justia Law

The Supreme Court held that no statute expressly authorizes a school district to retain a lawyer on a contingent-fee basis to prosecute litigation designed to increase the appraised value of property so as to generate more tax receipts for the school district and that authority for such an arrangement cannot be implied from a school district's express authority to bring litigation regarding appraisals.Iraan-Sheffield Independent School District employed attorney D. Brent Lemon on a contingent-fee basis to pursue claims designed to increase the appraised value of property so as to generate more tax receipts. After the Appraisal Review Board denied the challenge the school district appealed. The district court granted Defendants' Rule 12 motion challenging Lemon's authority to represent the school district and then dismissed the case with prejudice. The court of appeals reversed, concluding that Tex. Tax Code 6.30(c) authorized the contingent-fee arrangement. The Supreme Court affirmed on different grounds and remanded the case, holding that the district court (1) correctly granted Defendants' Rule 12 motion; but (2) erred in dismissing the case with prejudice. View "Pecos County Appraisal District v. Iraan-Sheffield Independent School District" on Justia Law

The Supreme Court reversed the opinion of the court of appeals reversing the trial court's holding that, as a matter of law, a statutory "safe-harbor" provision applied and relieved an operator of oil-and-gas wells from any obligation to pay interest in the amounts withheld, holding that the safe-harbor provision applied as a matter of law.At issue was the "safe harbor" provision that permits operators to withhold payments without interest under certain circumstances. In reliance with the safe harbor provision the operator in this case withheld production payments it was contractually obligated to make to one of the wells' owners. The owner brought suit seeking to recover the payments with interest. The operator made the payments but without interest. The trial court concluded that the safe-harbor provision allowed the operator to withhold the funds. The court of appeals reversed. The Supreme Court reversed, holding that the operator established as a matter of law that it was entitled to withhold distribution of production payments without interest under the statutory safe-harbor provision of Tex. Nat. Res. Code 91.402(b)(1)(A) and (b)(1)(B)(ii). View "Freeport McMoRan Oil & Gas LLC v. 1776 Energy Partners, LLC" on Justia Law

The Supreme Court held that a Hidalgo County court at law had jurisdiction over a civil case within the $750,000 limit involving the foreclosure of a lien on land.The McMasters executed a deed of trust to Ditech Servicing, LLC to secure a loan to purchase property. Thereafter, Jerry Perez acquired the property at a sheriff's sale to enforce a judgment. When the McMasters defaulted on their note Ditech initiated nonjudicial foreclosure proceedings. Perez subsequently sued Ditech in County Court seeking a declaration that Ditech had waived its right to foreclose. Ditech counterclaimed for judicial foreclosure. The trial court ultimately granted summary judgment for Ditech. The court of appeals vacated the trial court's judgment and dismissed the case for want of jurisdiction, concluding that the trial court had no jurisdiction under Tex. Gov't Code 26.043. The Supreme Court reversed and entered judgment for Ditech, holding (1) suits for the enforcement of a lien on land or for the recovery of land are "civil cases" over which a district court has jurisdiction; and (2) where the amount in controversy was less than $750,000, the Hidalgo County court at law had jurisdiction over Ditech's counterclaim. View "Ditech Servicing, LLC v. Perez" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals in this products-liability case concluding that the exercise of personal jurisdiction over Defendants was consistent with due process, holding that the minimum-contacts analysis requires evaluation of a defendant's contacts with the forum - Texas - as a whole.Plaintiff was injured when he used a lithium-ion battery that he bought at a store in Texas and used it to charge his e-cigarette. Although Defendants sold and distributed the batteries to manufacturers in Texas they argued that Texas courts lacked personal jurisdiction because they did not send the batteries to Texas for resale to individual consumers to use with e-cigarettes. Specifically, Defendants argued that Plaintiff's claims arose out of the use of the battery in a way Defendants never intended by an individual consumer they never targeted. The lower courts concluded that the exercise of personal jurisdiction over Defendants was consistent with due process. The Supreme Court affirmed, holding that the relatedness prong of the minimum-contacts analysis does not require that the plaintiff's claims arose out of a set of facts mirroring the defendant's expectations about the course its product would follow after entering the state of Texas. View "LG Chem America, Inc. v. Morgan" on Justia Law