Justia Texas Supreme Court Opinion Summaries

In this interlocutory appeal involving the application of a statutory immunity waiver in a lawsuit alleging breach of a contract to construct university housing the Supreme Court reversed the decision of the court of appeals reversing the trial court's ruling that the university was not immune from suit, holding that the court of appeals erred.In 2014, Texas Southern University (TSU) executed a contract with Pepper Lawson Horizon International Group, LLC (PLH) to work as the contractor on a project to construct student housing. PLH later sued TSU for breach of contract. TSU asserted sovereign immunity to suit as a defense despite PLH's pleadings expressly invoking the immunity waiver in Tex. Civ. Prac. & Rem. Code 114.003, arguing that section 114.003 was inapplicable because PLH failed to plead a claim covered by the waiver provision. The trial court denied TSU's plea to the jurisdiction, but the court of appeals reversed. The Supreme Court reversed, holding that the court of appeals erred in concluding that PLH failed to plea a cognizable Chapter 114 claim. View "Pepper Lawson Horizon Int'l Group, LLC v. Tex. Southern University" on Justia Law

In this proceeding brought by one political subdivision against another the Supreme Court held that sovereign immunity did not apply in this context, thus reversing the conclusion of the court of appeals that the condemnee entity was immune from suit and that the trial court's order granting the condemnee entity's plea to the jurisdiction was without error.Hidalgo County Water Improvement District No. 3 (the Improvement District) offered to purchase subsurface easement from Hidalgo County Irrigation District No. 1 (the Irrigation District) in order to extend an irrigation pipeline. After the Irrigation District rejected the offer the Improvement District filed this condemnation action. The commissioners awarded the Irrigation District $1,900 in damages, and before the trial court ruled on its objection, the Irrigation District filed a plea to the jurisdiction. The trial court granted the plea, concluding that the Irrigation District had governmental immunity from the condemnation suit. The court of appeals affirmed. The Supreme Court reversed, holding that sovereign immunity does not apply in eminent domain proceedings and that the Irrigation District was not immune from the Improvement District's condemnation suit. View "Hidalgo County Water Improvement District No. 3 v. Hidalgo County irrigation District No. 1" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the decision of the district court denying Winstead PC's motion to dismiss USA Lending Group, Inc.'s malpractice claim brought under the Texas Citizens Participation Act in this legal malpractice case, holding that Winstead presented prima facie evidence sufficient to survive a motion to dismiss.USA Lending hired Winstead PC to sue USA Lending's former employee. Later, USA Lending sued Winstead and its attorney seeking more than $1 million in damages, alleging that Winstead's malpractice caused USA Lending to forfeit its claim for monetary damages. Winstead filed a motion to dismiss, arguing that the lawsuit was based on its exercise of the right to petition. The district court denied the motion, but the court of appeals reversed. The Supreme Court reversed, holding that USA Lending adduced prima facie evidence to support its claim for legal malpractice. View "USA Lending Group, Inc. v. Winstead PC" on Justia Law

The Supreme Court affirmed the conclusion of the court of appeals on remand that PNC Mortgage's foreclosure claim was time-barred, holding that there was no error.PNC, whose predecessor refinanced John and Amy Howards' original mortgage loans, did not initiate foreclosure proceedings until its claim to enforce its own lien was time-barred under the relevant statute of limitations. On appeal, the court of appeals concluded that the common-law doctrine of equitable subrogation did not provide PNC with an alternative means of disclosure. The Supreme Court reversed and remanded with instructions to address the Howards' claim that PNC's equitable subrogation claim was time-barred. On remand, the court of appeals concluded that the equitable subrogation claim was time-barred. The Supreme Court affirmed, holding that PNC's claim was time-barred. View "PNC Mortgage v. Howard" on Justia Law

The Supreme Court conditionally granted relief in this mandamus proceeding arising out of a dispute between Property Owners and a Homeowners Association (HOA) regarding enforcement of amended restrictive covenants, holding that the trial court abused its discretion in compelling joinder of the other owners.Property Owners sued the HOA in this case requesting a declaratory judgment that the amended restrictions could not be enforced against them because the required percentage of owners did not approve the amended restrictions. The trial court granted the HOA's motion to abate the claims until Property Owners joined all 700 other owners in the subdivision as parties or face dismissal of their suit. The court of appeals denied Property Owners' ensuing petition for writ of mandamus. The Supreme Court granted a writ of mandamus and ordered the trial court to vacate its order, holding that the trial court clearly abused its discretion in granting the motion to abate and ordering Property Owners to join the other property owners and that Property Owners lacked an adequate remedy by appeal. View "In re Kappmeyer" on Justia Law

The Supreme Court reversed in part the opinion of the court of appeals in this interlocutory appeal concerning whether a subsequent purchaser (Purchaser) of a home is required to arbitrate her claims against the builder (Builder) for alleged construction defects, holding that the trial court erred in granting Purchaser's motion to vacate and denying Builder's motion to confirm.The trial court granted the motion to compel arbitration filed by Builder, which joined two subcontractors in the arbitration, asserting that they owed defense and indemnity obligations. The arbitrator issued an award in favor of Builder. The trial court vacated the award against Purchaser but made no ruling whether to vacate the award against the subcontractors. The Supreme Court rendered judgment confirming the award against Purchaser and remanded the case, holding (1) Purchaser was bound by the arbitration clause in the purchase-and-sale agreement under the doctrine of direct-benefits estoppel; and (2) because the record contained no ruling on whether to vacate the award against the subcontractors, remand was required. View "Lennar Homes of Tex. Land & Construction, Ltd. v. Whiteley" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the trial court's conclusion that contract language releasing claims against a named entity's predecessors barred the releasor's recovery against an unaffiliated and unrelated predecessor in title, holding that the court of appeals correctly rendered judgment that, as used in the release agreement, the term "predecessors" refers only to corporate predecessors.On appeal, Appellants argued that the neither the contract language nor the circumstances surrounding the execution of the release supported limiting the term "predecessors" to "corporate" predecessors and that "predecessors" naturally refers to predecessors in title. The Supreme Court affirmed, holding (1) the release was not ambiguous as to the meaning of "predecessors"; and (2) Appellees were entitled to summary judgment on the affirmative defenses of release, waiver, and third-party beneficiary. View "Finley Resources, Inc. v. Headington Royalty, Inc." on Justia Law

The Supreme Court reversed the judgment of the court of appeals on a survival claim brought by the estate of Clark Davis against United Rentals North America, Inc., rendered a take nothing judgment on this claim, and remanded the case to the district court for a new trial on the remaining claims, holding that racial considerations impermissibly tainted the selection of the jury in the underlying trial.During jury selection, Plaintiffs' counsel stated that "the African-American female was the most favorable juror in this case," and this announced preference was consistent with Plaintiffs' peremptory strikes. The jury returned a verdict for Plaintiffs, and the district court awarded $5 million to Davis's estate. The court of appeals affirmed. The Supreme Court reversed, holding that a new trial was required because counsel stated a racial preference in jury selection, the peremptory strikes were consistent with that preference, and the district court did not remedy the issue. View "United Rentals North America, Inc. v. Evans" on Justia Law

The Supreme Court conditionally granted relief in this mandamus proceeding concerning a motion to compel a medical examination under Tex. R. Civ. P. 204.1, holding that the trial court clearly abused its discretion in denying the motion.Marcos Acosta brought this action alleging that he was injured in an automobile accident caused by the negligence of Roberto Hernandez, who was working for The Sherwin-Williams Company at the time, and seeking damages for, among other things, medical expenses and physical pain. The defendants moved to compel a medical examination of Acosta by their designated expert, but the trial court denied the motion to compel the exam. The court of appeals denied mandamus relief. The Supreme Court conditionally granted relief and directed the trial court to issue an order compelling Acosta to submit to the proposed examination, holding that the defendants showed good cause to compel a medical examination of Acosta. View "In re Sherwin-Williams Co." on Justia Law

In this "highly unusual" personal jurisdiction dispute the Supreme Court held that Texas courts have specific jurisdiction over German automobile manufacturers based on their intentional post-sale tampering with affected vehicles that were owned, operated, and serviced in Texas.The State and several local governments brought civil actions to enforce state environmental laws against Defendants - German automobile manufacturers that intentionally evaded federal emissions standards by embedding illegal emissions-defeating technology in graded vehicles. At issue was whether the manufacturers' contacts with Texas satisfied the constitutional requisites to exercising specific personal jurisdiction. The trial court ruled that the manufacturers were amenable to specific personal jurisdiction in Texas, but the court of appeals reversed. The Supreme Court reversed, holding that where the manufacturers developed the product, controlled the distribution stream that brought the product to Texas, and "called all the shots," the trial court did not err in exercising specific personal jurisdiction over the German manufacturers. View "State v. Volkswagen Aktiengesellschaft" on Justia Law