Justia Texas Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals affirming the decision of the trial court denying the Health and Human Services Commission's (HHSC) combined plea to the jurisdiction and motion for summary judgment, holding that Plaintiffs' conduct was not protected by the Texas Whistleblower Act.Plaintiffs sued HHSC under the Act, alleging that they were terminated in retaliation for their good faith reports about violations of law by HHSC to various law enforcement agencies. HHSC responded by filing a combined plea to the jurisdiction and motion for summary judgment. The trial court denied the plea and motion, and the court of appeals affirmed. The Supreme Court reversed, holding that Plaintiffs' reports of misconduct could not support a Whistleblower Act claim against HHSC. View "Tex. Health & Human Services Comm'n v. Pope" on Justia Law

The Supreme Court reversed in part the judgment of the court of appeals in this insurance dispute, holding that Tex. Ins. Code 705.051 does not displace the common-law rule that insurers may not avoid liability under an insurance policy based on a misrepresentation in an insurance application unless the insurer pleads and proves the insured intended to deceive or induce the insurer to issue the policy.At issue was whether the common-law scienter requirement was repugnant to the plain language of section 705.051, which provides that a misrepresentation in an application for an insurance policy does not defeat recovery under the policy unless the misrepresentation is of a material fact and affects the risks assumed. The court of appeals held that the common-law scienter requirement survived section 705.051's recodification, and therefore, summary judgment was not proper. The Supreme Court affirmed in part, holding (1) section 705.051 does not displace the common-law rule; and (2) as a matter of law, the insurer in this case was exempt from complying with the ninety-day notice provision in Texas Ins. Code 705.005. View "American Nat'l Insurance Co. v. Arce" on Justia Law

The Supreme Court reversed the judgment of the court of appeals in this contract dispute, holding that the court of appeals erred by failing to apply a common-law default rule to the parties' dispute involving the sale of working interests in 109 oil-and-gas leases.According to the Court, Texas cases have long followed a default common-law rule in the circumstances that the words "from" or "after" a specific date to measure a length of time. Under the rule, courts must treat the time period as excluding the specified date (measuring date), and therefore, a period measured in years "from" or "after" a measuring date ends on the anniversary of the measuring date, not the day before. In the instant case, the parties asked the Supreme Court to resolve key issues of contract construction. Noting that the parties could have easily departed from the default rule by indicating as much within the four corners of the relevant lease, the Supreme Court held that because the parties' agreement implicated the default rule without displacing it, the default rule must be applied to the dispute. View "Apache Corp. Apollo Exploration, LLC" on Justia Law

The Supreme Court held that Tex. Civ. Prac. & Rem. Code Ann. 16.063 did not toll the running of the statute of limitations during Defendant's physical absence from Texas.At issue was whether section 16.063 applies to toll the when the defendant leaves the state for part of the limitations period but remains a Texas resident subject to personal jurisdiction in Texas amenable to service under the Texas long-arm statute. Defendant lived in Texas at the time that she was involved in a car accident with Plaintiff but subsequently moved to Massachusetts to attend school. Defendant, however, returned to Texas during breaks, maintained a Texas mailing address, and kept her Texas driver license. Plaintiff tried serving Defendant at her family's Texas home without success. When Defendant was finally served she successfully moved for summary judgment based on the statute of limitations. Plaintiff appealed, challenging the court's application of Ashley v. Hawkins, 293 S.W.3d 175 (Tex. 2009), to this case. The Supreme Court affirmed, holding that if a defendant is subject to personal jurisdiction in Texas and amenable to service, she is not absent from the state under section 16.063. View "Ferrer v. Almanza" on Justia Law

The Supreme Court conditionally granted Defendants' petition for mandamus relief from the trial court's order striking their counteraffidavit served under Tex. Civ. Prac. & Rem. Code 18.001, holding that the trial court's order was an abuse of discretion for which Defendants lacked an adequate remedy by appeal.Plaintiff sued Defendants for negligence. At issue was the counteraffidavit and testimony of Dr. Benny Sanchez, who was retained by Defendants as an expert witness. Plaintiff moved to strike Dr. Sanchez's counteraffidavit and testimony, arguing that the counteraffidavit improperly challenged the cause of Plaintiff's injuries, not the necessity of his treatment. The trial court granted the motion. Thereafter, the trial court issued its opinion in Allstate. Defendants later brought this petition seeking a writ of mandamus and citing In re Allstate Indemnity Insurance Co., 622 S.W.3d 870 (Tex. 2021), in support of their argument that the trial court abused its discretion. The Supreme Court agreed and conditionally granted the writ, holding that the trial court clearly abused its discretion by striking Dr. Sanchez's counteraffidavit and testimony, and Defendants lacked an adequate remedy to address this error by way of appeal. View "In re Chefs' Product of Houston, Inc." on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming a modified version of the order of the district court certifying a class, holding that when the claims for which the plaintiffs seek class certification have no basis in law, even taking all the allegations as true, class certification cannot be granted.Tenants sued Landlord alleging a violation of Tex. Prop. Code 92.056(g), arguing that Landlord was strictly liable for omitting a required lease term. Tenants sought class certification of a class of more than 65,000 former tenants. Landlord moved for summary judgment, arguing that the lawsuit amounted to an "ineffectual[] attempt to manufacture strict-liability requirements and civil-penalty remedies that do not exist under a plain reading of the Texas Property Code." The district court granted the motion for class certification, and the court of appeals affirmed as modified. The Supreme Court reversed, holding that where Tenants' proposed class claims had no basis law, the "rigorous analysis" necessary to certify the class could not meaningfully be performed. View "American Campus Communities, Inc. v. Berry" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the trial court ruling that one of two proposed amendments to the City of Houston's charter approved by voters restricted the effectiveness of the other ballot measure, holding that on amendment included a "primary clause" that was void because it conflicted with state law.One of the amendments at the issue was submitted at the behest of the City Council, and the other was initiated by local citizens. The election ordinance included a "primacy clause" providing that the Council's proposition would prevail over the citizen-initiated proposition if voters approved the Council’s proposition by more votes than the citizens’ proposed amendment. The voters approved both amendments. The City brought suit, arguing that the second amendment did not become effective upon its adoption due to the primacy clause. Relying on the primacy clause, the trial court granted summary judgment for the City. The court of appeals affirmed. The Supreme Court reversed and remanded the case, holding (1) the primacy conflicts with state law requiring that a city must adopt a charter amendment upon its approval by a majority vote; and (2) therefore, the City may not rely on the primacy clause to avoid complying with the citizen-initiated proposition. View "Hotze v. Turner" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the trial court's order certifying a class in this action claiming violations of Tex. Prop. Code 92.019, which regulates landlords' ability to impose late fees on tenants who untimely pay their rent, holding that the trial court abused its discretion by failing to address Petitioners' defenses in the trial plan and their effects on the requirement for class certification.Respondent sued Petitioners for breach of Tex. Prop. Code 92.019 for charging and collecting late fees and charging back rent concessions. Respondent later moved for class certification. After a hearing, the trial court granted the motion. The court of appeals affirmed. The Supreme Court reversed, holding that the trial court abused its discretion by failing correctly to identify the elements of Petitioners' defenses in the trial plan and address their effect on the requirements for class certification in violation of Tex. R. Civ. P. 42(c)(1)(D). View "Mosaic Baybrook Once, L.P. v. Cessor" on Justia Law

In this mineral lease dispute, the Supreme Court reversed the judgment of the court of appeals concluding that a lease deadline and untimely scheduled drilling date were irrelevant for invoking a force majeure clause and thus reversing the trial court's judgment and remanding the case, holding that the court of appeals erred.In reversing the trial court's judgment, the court of appeals determined that fact issues existed both as to whether the force majeure clause applied and as to each element of the lessee's tortious-interference claims. The Supreme Court reversed and remanded the case, holding (1) construed in context, the phrase "Lessee's operations are delayed by an event of force majeure" does not refer to the delay of a necessary drilling operation already scheduled to occur after the deadline for perpetuating the lease; (2) the force majeure clause in this case did not save the lease; and (3) to the extent the lessee's tortious-interference claims were predicated on the force majeure clause's saving the lease, a take-nothing judgment is rendered in part. View "Point Energy Partners Permian, LLC v. MRC Permian Co." on Justia Law

In this dispute over a "Water/Sewer Base Fee" that Landlords billed tenants each month to recover certain amounts it had paid the municipal utility district the Supreme Court affirmed the trial court's grant of partial summary judgment in Tenant's favor and the court of appeals' judgment affirming the trial court's order certifying a class under Rule 24 of the Texas Rules of Civil Procedure, holding that there was no error.Tenant brought suit against Landlords challenging a fee that included not only each apartment's allocated portion of the utility's customer service charge for water and sewer service but also an undisclosed amount equivalent to a portion of the utility's charges for non-water emergency services. Tenant sued under the Water Code on behalf of a tenant class. The trial court granted Landlords' motion for partial summary judgment on liability and certified a class. The Supreme Court affirmed, holding that the trial court (1) did not err in granting partial summary judgment; and (2) did not abuse its discretion in certifying the class. View "Mosaic Baybrook One, L.P. v. Simien" on Justia Law