Justia Texas Supreme Court Opinion Summaries

The case involves The Boeing Company and the Southwest Airlines Pilots Association (SWAPA). Boeing introduced the 737 MAX in 2011, which was marketed as more fuel-efficient and similar to previous models, requiring no additional pilot training. However, two crashes in 2018 and 2019 led to the grounding of the MAX. SWAPA, representing Southwest pilots, had agreed to fly the MAX but later sued Boeing, claiming Boeing interfered with their business relationship with Southwest and fraudulently induced them to fly the MAX without proper training.The trial court dismissed SWAPA's claims with prejudice, agreeing with Boeing that the Railway Labor Act preempted the claims and that SWAPA lacked standing. SWAPA appealed, and the Court of Appeals for the Fifth District of Texas held that the Act did not preempt the claims, SWAPA lacked associational standing, but had standing to assert claims on its own behalf. The court also ruled that the assignments of claims from individual pilots to SWAPA were valid but did not retroactively grant standing in the original suit, leading to a partial dismissal without prejudice.The Supreme Court of Texas reviewed the case and concluded that the Railway Labor Act does not preempt SWAPA’s claims because their resolution does not require interpretation of the collective bargaining agreements (CBAs). The court also held that the assignments of claims from pilots to SWAPA are not void against public policy, allowing SWAPA to pursue these claims as an assignee. The court affirmed the appellate court’s judgment, remanding the case to the trial court for further proceedings on the claims SWAPA asserts on its own behalf. View "The Boeing Company v. Southwest Airlines Pilots Association" on Justia Law

Gary Perez and Matilde Torres, members of the Lipan-Apache Native American Church, believe that certain religious services must be conducted at a specific site within Brackenridge Park in San Antonio, Texas. The City of San Antonio planned improvements to the park, including tree removal and bird deterrence, which Perez and Torres argued would destroy their sacred worship space. They sued the City, claiming violations of their religious rights under the First Amendment, the Texas Constitution, the Texas Religious Freedom Restoration Act (RFRA), and a new clause in the Texas Constitution that prohibits limiting religious services.The federal district court granted limited relief, allowing the Church access for certain ceremonies but did not enjoin the City's improvement plans. Perez appealed, and the Fifth Circuit initially affirmed the district court's decision but later withdrew its opinion and certified a question to the Supreme Court of Texas regarding the scope and force of the new Texas Religious Services Clause.The Supreme Court of Texas held that the Texas Religious Services Clause imposes a categorical bar on governmental limitations of religious services, regardless of the government's interest in the limitation. However, the Court also concluded that the scope of the clause is not unlimited and does not extend to the government's preservation and management of publicly owned lands. The Court emphasized that the clause does not require the government to provide or maintain natural elements necessary for religious services on public property. The case was remanded to the federal courts for further proceedings consistent with this interpretation. View "PEREZ v. CITY OF SAN ANTONIO" on Justia Law

White Knight Development, LLC entered into a contract in 2015 to purchase land from Dick and Julie Simmons for $400,000. The contract included a "buy-back" provision allowing White Knight to require the Simmonses to repurchase the property if certain restrictions were extended. When the restrictions were extended in October 2016, White Knight invoked the buy-back provision, but the Simmonses refused to repurchase the property. White Knight sued for breach of contract and sought specific performance and damages related to the delay in performance.The trial court found that the Simmonses breached the contract and awarded White Knight specific performance, ordering the Simmonses to repurchase the property for $400,000. Additionally, the court awarded White Knight $308,136.14 in damages for various costs incurred due to the delay in performance. These costs included property taxes, loan interest, and other expenses related to the property and White Knight's business operations.The Court of Appeals for the Tenth District of Texas modified the judgment by deleting the $308,136.14 monetary award but otherwise affirmed the trial court's decision. The court acknowledged that monetary compensation could be awarded alongside specific performance in narrow circumstances but found no express statement by the trial court that the monetary award was equitable in nature.The Supreme Court of Texas held that while specific performance usually precludes a monetary award, there are narrow circumstances where both can be awarded. The court concluded that the trial court's findings supported an equitable monetary award to account for the delay in performance. The Supreme Court reversed the Court of Appeals' judgment in part and remanded the case for further review of the monetary award consistent with the principles announced. View "WHITE KNIGHT DEVELOPMENT, LLC v. SIMMONS" on Justia Law

A landowner recorded a plat dividing its property into seventy-three tracts, each between one and two acres. A restriction in the recorded deeds stated that no more than two residences could be built on any five-acre tract. Neighbors sued to enforce this restriction, arguing it limited development to no more than two residences per five acres.The trial court granted partial summary judgment for the neighbors, holding the restriction unambiguously limited development to two residences per five-acre tract. The court dismissed the landowner's defenses and counterclaims, except for changed conditions, and issued a temporary injunction. The jury found no changed conditions, and the court permanently enjoined the landowner from building more than two residences per five-acre tract. The court of appeals affirmed, holding the restriction unambiguously limited development and rejecting the landowner's defenses.The Supreme Court of Texas reviewed the case and held that the restriction did not prevent the landowner from building one residence on each sub-five-acre tract. The court concluded that the restriction limited density, not tract size, and did not expressly address tracts smaller than five acres. The court reversed the judgment awarding the neighbors declaratory and injunctive relief and remanded for a new trial on the landowner's changed-conditions counterclaim, finding the jury was improperly instructed to consider only post-purchase changes. The court also held that nonparty adjoining landowners and the State were not necessary parties to the suit. View "EIS DEVELOPMENT II, LLC v. BUENA VISTA AREA ASSOCIATION" on Justia Law

Rita Oteka, a faculty member at The University of Texas Rio Grande Valley, attended a commencement ceremony voluntarily. While walking to her car after the event, she was struck and injured by a vehicle driven by a University police officer. The University, a self-insured employer for workers' compensation, reported the injury to its third-party claims administrator. The administrator denied benefits, stating that Oteka was using her personal insurance, no medical evidence was presented, and the injury was not work-related. Oteka did not contest this denial or file a compensation claim.Oteka later sued the police officer for negligence, and the University substituted in as the defendant. The University claimed that workers' compensation benefits were the exclusive remedy for Oteka's injury, asserting for the first time that the injury was work-related. The district court denied the University's plea to the jurisdiction, and the University appealed. The Court of Appeals for the Thirteenth District of Texas affirmed, holding that the Division of Workers' Compensation did not have exclusive jurisdiction over the course-and-scope issue in this context.The Supreme Court of Texas reviewed the case and held that the Division does not have exclusive jurisdiction to determine whether an injury was work-related when the issue is raised by an employer's exclusive-remedy defense and the employee's lawsuit does not depend on entitlement to workers' compensation benefits. The court affirmed the lower court's judgment, emphasizing that the Workers' Compensation Act does not provide a procedural mechanism for obtaining a course-and-scope finding from the Division without the employee first filing a compensation claim. View "THE UNIVERSITY OF TEXAS RIO GRANDE VALLEY v. OTEKA" on Justia Law

In April 2022, six-year-old Emory Sayre was killed by her school bus in Parker County, Texas. The bus was manufactured by Blue Bird Body Company and sold by Rush Truck Centers of Texas to Brock Independent School District. Emory's parents, Sean and Tori Sayre, filed a lawsuit in Dallas County against Rush Truck and Blue Bird, asserting various claims including strict liability and negligence. They argued that venue was proper in Dallas County due to several activities related to the bus sale occurring there.The trial court denied the defendants' motion to transfer venue to Parker or Comal County. Rush Truck and Blue Bird filed an interlocutory appeal, which the Court of Appeals for the Fifth District of Texas affirmed, holding that a substantial part of the events giving rise to the claims occurred in Dallas County.The Supreme Court of Texas reviewed the case and focused on whether the Court of Appeals had jurisdiction to entertain the interlocutory appeal. The Court held that Section 15.003(b) of the Texas Civil Practice and Remedies Code permits interlocutory appeals only in cases where a plaintiff’s independent claim to venue is at issue. Since the Sayres asserted identical claims based on identical facts with identical venue grounds, the trial court did not need to determine whether each plaintiff independently established proper venue. Therefore, the Court of Appeals erred in taking jurisdiction of the interlocutory appeal.The Supreme Court of Texas vacated the judgment of the Court of Appeals and remanded the case to the district court for further proceedings. View "Rush Truck Centers of Texas, L.P. v. Sayre" on Justia Law

A service dog attacked a young child in a restaurant, leading the child's parents to sue several parties, including a medical doctor who had written letters for the dog's owner, stating that her service animals helped with her anxiety disorder. The parents did not dispute the doctor's diagnosis but argued that he was negligent for not verifying whether the dog was appropriately trained as a service animal, which they claimed led to their daughter's injuries.The trial court denied the doctor's motion to dismiss, which argued that the claims were health care liability claims (HCLCs) requiring an expert report. The Court of Appeals affirmed, stating that the claims did not concern the doctor's medical diagnosis or treatment and thus did not constitute HCLCs.The Supreme Court of Texas reviewed the case and concluded that the claims against the doctor were not HCLCs. The court held that the doctor's failure to verify the dog's training did not involve a departure from accepted standards of medical care. Therefore, an expert report was not required. The court affirmed the lower courts' decisions and remanded the case for further proceedings. View "Leibman v. Waldroup" on Justia Law

The Texas Attorney General alleged that Annunciation House, a nonprofit organization in El Paso, was unlawfully harboring illegal aliens. The Attorney General sought to examine the organization's records and initiate quo warranto proceedings, which could lead to the revocation of its charter. Annunciation House, which provides shelter to immigrants and refugees, was served with a records request by state officials, who demanded immediate compliance. Annunciation House sought legal relief, arguing that the request violated its constitutional rights.The 205th Judicial District Court in El Paso County granted a temporary restraining order and later a temporary injunction against the Attorney General's records request. The court also denied the Attorney General's motion for leave to file a quo warranto action, ruling that the statutes authorizing the records request were unconstitutional and that the allegations of harboring illegal aliens did not constitute a valid basis for quo warranto. The court further held that the statutes were preempted by federal law and violated the Texas Religious Freedom Restoration Act (RFRA).The Supreme Court of Texas reviewed the case on direct appeal. The court held that the trial court erred in its constitutional rulings and that the Attorney General has the constitutional authority to file a quo warranto action. The court emphasized that it was too early to express a view on the merits of the underlying issues and that the usual litigation process should unfold. The court also held that the statutes authorizing the records request were not facially unconstitutional and that the trial court's injunction against the Attorney General's records request was improper. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "PAXTON v. ANNUNCIATION HOUSE, INC." on Justia Law

The case involves a challenge to a Texas Department of Family and Protective Services (DFPS) rule that authorized state licenses for two residential facilities where the federal government detained mothers and children after their illegal entry into the United States. The plaintiffs, including detained mothers and Grassroots Leadership, Inc., sought to prohibit the detention of children at these facilities, arguing that the rule was invalid under state law. However, by the time the case reached the court of appeals, all the mothers and children had been released from the facilities.The trial court denied the pleas to the jurisdiction filed by the department and the facility operators, eventually ruling in favor of the plaintiffs by declaring the rule invalid and enjoining the department from granting licenses under it. The Third Court of Appeals reversed, holding that the plaintiffs lacked standing and that their claims were moot since they were no longer detained. However, the court of appeals proceeded to address the merits of the case by invoking the "public-interest exception" to mootness and held the rule invalid under the Administrative Procedure Act.The Supreme Court of Texas reviewed the case and held that Texas courts are not constitutionally authorized to adjudicate moot cases, even if they raise questions of considerable public importance. The court emphasized that mootness is a constitutional limitation on judicial power, and there is no "public-interest exception" to mootness in Texas. Consequently, the court reversed the court of appeals' judgment regarding its jurisdiction, vacated the judgment on the merits, and dismissed the case for lack of subject-matter jurisdiction. View "TEXAS DEPARTMENT OF FAMILY AND PROTECTIVE SERVICES v. GRASSROOTS LEADERSHIP, INC" on Justia Law

Cheryl Butler was hired as an assistant law professor at Southern Methodist University (SMU) in 2011. After a mandatory third-year performance review, her contract was renewed, and she became eligible for tenure consideration in the fall semester of 2015. Due to illness, Butler requested an extension of the tenure vote, which was denied, but she was later granted leave under the Family Medical Leave Act (FMLA) for the spring semester of 2016. Her tenure committee, chaired by Professor Roy Anderson, concluded that Butler met tenure standards for scholarship and service but not teaching. Consequently, the law faculty voted not to recommend tenure, and Butler's appeals to the SMU Law School Dean and the Provost were unsuccessful. Butler completed the 2016-2017 academic year without teaching any classes.Butler filed a lawsuit against SMU and several of its employees, alleging racially discriminatory tenure standards and processes, and retaliation for her internal complaints about race, disability, and FMLA discrimination. She brought federal statutory claims under 42 U.S.C. § 1981, Title VII of the Civil Rights Act of 1964, the Rehabilitation Act of 1973, the Americans with Disabilities Act, Title IX, and the FMLA. Additionally, she asserted state-law discrimination and retaliation claims under Texas Labor Code Chapter 21, along with state common law claims for breach of contract and negligent supervision. Against the employee defendants, she claimed defamation, conspiracy to defame, and fraud.The United States District Court for the Northern District of Texas dismissed Butler's defamation and fraud claims against the employee defendants, citing preemption by Chapter 21 of the Texas Labor Code. The court held that the gravamen of these claims was unlawful employment discrimination and retaliation, which Chapter 21 specifically addresses. Butler appealed, and the United States Court of Appeals for the Fifth Circuit certified a question to the Supreme Court of Texas regarding whether Chapter 21 preempts common law defamation and fraud claims against employees based on the same conduct as discrimination claims against the employer.The Supreme Court of Texas held that Chapter 21 does not preempt common law defamation and fraud claims against employees. The court reasoned that Chapter 21 subjects only employers to liability for discriminatory and retaliatory conduct and does not immunize individuals from liability for their own tortious actions. Therefore, Butler's defamation and fraud claims against the employee defendants are not foreclosed by Chapter 21. View "BUTLER v. COLLINS" on Justia Law