Justia Texas Supreme Court Opinion Summaries

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The Supreme Court reversed the judgment of the court of appeals concluding that an insurer's payment of an appraisal award barred an insured's claims under the Texas Prompt Payment of Claims Act (TPPCA), Tex. Ins. Code chapter 542, holding that payment of an appraisal award does not extinguish TPPCA liability as a matter of law.After Insured's property sustained damage from a storm, Insurer valued the property damage at $5,153. Believing the property damage was undervalued, Insured sued, alleging breach of contract and extra-contractual claims and invoking the policy's appraisal clause. Appraisers valued the damage at almost $15,000. Insurer paid the balance of the award and then filed a motion for summary judgment. The trial court granted the motion. The court of appeals affirmed, concluding that, as a matter of law, Insured could not maintain his TPPCA claim because Insurer paid the appraisal award. The Supreme Court reversed and remanded the case, holding that the court of appeals' opinion was inconsistent with this Court's recent decisions on the issue. View "Perry v. United Services Automobile Ass'n" on Justia Law

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This case case arising out of the breakup of a limited partnership created to produce and market a new cement product the Supreme Court reversed in part the judgment of the court of appeals largely affirming the judgment of the trial court in favor of the limited partnership and a technology-supplying partner, holding that Plaintiffs failed to present legally sufficient evidence of damages and that the technology-supplying partner was not entitled to a permanent injunction for misappropriation of trade secrets.The partnership, its general partner, and the limited partner that supplied the cement-making technology sued the limited partners responsible for funding, the general manager of the partnership, and the companies that foreclosed on and purchased the partnership's assets. Defendants asserted counterclaims. The court of appeals largely affirmed. The Supreme Court reversed in part and affirmed in part, holding (1) the damage awards were not supported by legally sufficient evidence; (2) the technology-supplying partner was not entitled to a permanent injunction for misappropriation of trade secrets; and (3) the company that purchased the partnership's assets and promissory note did not prove it was entitled to judgment as a matter of law on its counterclaim for the partnership's failure to pay a deficiency balance on the note. View "Pike v. Texas EMC Management, LLC" on Justia Law

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The Supreme Court held that the Expedited Declaratory Judgment Act (EDJA), Tex. Gov't Code ch. 1205, gave the trial court jurisdiction to declare whether contracts executed by the San Jacinto River Authority were legal and valid but not whether the Authority complied with the contracts in setting specific water rates.The Authority, which has contracts to sell water to cities and other customers and uses the revenue to pay off its bonds, filed suit seeking declarations under the EDJA regarding the contracts and the water rates set under those contracts. Several participants, including three cities (Cities) opted in as interested parties. The Cities filed pleas to the jurisdiction, arguing that the trial court lacked subject matter jurisdiction to adjudicate the Authority's claims. The trial court denied the pleas to the jurisdiction. The court of appeals held primarily for the Authority. The Supreme Court held (2) the EDJA permits the trial court to exercise jurisdiction over the Authority's claims as to the valid execution of the contracts, but it does not confer jurisdiction over whether the Authority complied with the contracts in setting specific water rates; and (2) the Cities' governmental immunity does not bar an EDJA claim, which is brought in rem to adjudicate interests in property. View "City of Conroe, Texas v. San Jacinto River Authority" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals holding that the Texas Farm Animal Activity Act (the Act), Tex. Civ. Proc. & Rem. Code 87.001-87.005, does not apply to ranchers and ranch hands, holding that the court of appeals did not err.The Act limits liability for injury to "a participant in a farm animal activity or livestock show" that results from an "inherent risk" of those activities. Raul Zuniga worked full-time for Conway and Marlene Waak to work cattle on a ranch, landscape, and cut hay. Zuniga died after being trampled. Plaintiffs, Zuniga's family, sued the Waaks, on wrongful death and survival claims. The trial court granted summary judgment for the Waaks, concluding that the Act barred Plaintiffs' claims. The court of appeals reversed, concluding that Zuniga was not "a participant in a farm animal activity" for whose injuries and death the Act limits liability. The Supreme Court affirmed, holding that the Act does not cover ranchers and ranch hands and, therefore, did not shield the Waaks from liability for their negligence resulting in Zuniga's death. View "Waak v. Rodriguez" on Justia Law

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The Supreme Court reversed the decision of the court of appeals holding that a forum-selection clause in a contract bound all involved parties even where the only signatories did not assert any claims against one another, holding that the court of appeals erred in construing the contract containing the forum-selection clause and a contract that did not as a single, unified instrument and by applying the transaction-participant enforcement theory.Personal jurisdiction over two nonresident individuals and a nonresident LLC was premised on a forum-selection clause in a contract the nonresident LLC executed with a resident LLC. A signatory LLC sought to enforce the clause against nonsignatory individuals, and nonsignatory individuals sought to enforce the clause against nonsignatory individuals and a signatory LLC. The court of appeals concluded that all defendants were amenable to suit in Texas regardless of their status as a signatory. The Supreme Court reversed, holding (1) the separately executed instruments considered by the court of appeals were not part of a single, unified instrument and, therefore, must be construed separately; and (2) the transaction participant enforcement theory relied upon by the court of appeals was inapplicable. View "Rieder v. Woods" on Justia Law

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The Supreme Court reversed the judgment of the court of appeals on Plaintiff's survival action and rendered judgment for Defendant, holding that Plaintiff's claims were barred by the exclusive-remedy provision of the Texas Workers' Compensation Act because her evidence did not raise a fact issue under the intentional-injury exception to the Act's exclusive remedy.Plaintiff's husband, an employee of Defendant, a trucking and warehousing company, died when his rig ran off the highway and rolled over. Plaintiff filed suit, arguing that her husband fell asleep at the wheel due to the fatigue of being overworked. At issue was whether there was any evidence that Defendant believed the accident was substantially certain to result from Plaintiff's being overworked. The trial court granted summary judgment for Defendant. The court of appeals reversed. The Supreme Court reversed, holding that Plaintiff failed to raise a fact issue on the applicability of the intentional-injury exception to the exclusive-remedy provision of the Act. View "Mo-Vac Service Co., Inc." on Justia Law

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The Supreme Court concluded that, as to Plaintiffs' fraud claims, GTECH Corporation, a private contractor, would not qualify for derivative sovereign immunity for services it provided to the Texas Lottery Commission even if the Court recognized that doctrine but that GTECH was entitled to immunity from Plaintiffs' allegations of aiding and abetting the Commission's fraud and of conspiracy with the Commission.The Commission contracted with GTECH for instant ticket manufacturing and services. Plaintiffs filed two separate suits alleging that the instructions on a scratch-off lottery ticket mistakenly caused them to believe they had winning tickets. GTECH filed pleas to the jurisdiction, arguing that it was entitled to the Commission's immunity. The Dallas County trial court granted GTECH's plea to the jurisdiction. The Travis County trial court denied the plea. The Dallas Court of Appeals affirmed. The Austin Court of Appeals affirmed in part and reversed in part. The Supreme Court held (1) GTECH was not entitled to immunity from Plaintiffs' fraud claims because the Commission did not control GTECH's choices in writing the game instructions; and (2) GTECH was entitled to immunity from the theories of conspiracy and of aiding and abetting because Plaintiffs must necessarily override the substance of the Commission's underlying decisions in order to impose derivative liability on GTECH. View "GTECH Corp. v. Steele" on Justia Law

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The Supreme Court reversed the decision of the court of appeals affirming the judgment of the trial court concluding that a state agency violated the Texas Whistleblower Act, Tex. Gov't Code 554.002, when it fired one of its employees, holding that, under City of Fort Worth v. Zimlich, 29 S.W.3d 62 (Tex. 2000), no evidence demonstrated that the employee's report of a violation of state law more than one year earlier caused the agency to terminate the employee's employment.Laura Rodriguez, a regional manager for child-support services with the Office of the Attorney General, was fired fifteen months after reporting a violation of state law. Rodriguez sued the agency, claiming that it violated the Act because it fired her in retaliation for her protected activity. The trial court concluded that Rodriguez had made a good-faith report of a violation of law that caused the agency to terminate her employment. The court of appeals affirmed. The Supreme Court reversed, holding that the record evidence demonstrated that Rodriguez was fired based on conduct unrelated to her protected activity and that no evidence established that activity was a but-for cause of her termination. View "Office of Attorney General of Texas v. Rodriguez" on Justia Law

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In this labor dispute, the Supreme Court affirmed the judgment of the court of appeals reversing the order of the trial court granting Defendant's motion for judgment notwithstanding the verdict (JNOV), holding that Defendant did not carry its burden to establish that Plaintiff was its borrowed employee.Plaintiff sued Defendant for negligence after he was injured while working on an offshore drilling rig owned by Defendant. Although Plaintiff was not Defendant's employee, Defendant claimed that workers' compensation benefits were Plaintiff's sole remedy because Plaintiff was acting as its "borrowed employee" under the federal Longshore and Harbor Workers' Compensation Act (LHWCA). The jury found that Plaintiff was not Defendant's borrowed employee and awarded damages to Plaintiff. The trial court granted Defendant's JNOV motion, finding that the submission of the borrowed-employee question to the jury was improper and that the evidence supported Defendant's borrowed-employee defense. The court of appeals reversed, holding that the borrowed-employee inquiry can be a fact question for the jury. The Supreme Court affirmed, holding (1) the trial court correctly determined that the borrowed-employee inquiry was a legal question for the court, not a fact question for the jury; but (2) Defendant did not establish that Plaintiff was its borrowed employee. View "W&T Offshore, Inc. v. Fredieu" on Justia Law

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The Supreme Court held that a lack of immunity to COVID-19, without more, is not a "disability" that renders a voter eligible to vote by mail within the meaning of Tex. Elec. Code Ann. 82.002(a) and declined to issue a writ of mandamus sought by the State prohibiting Respondents, election officials, from improperly approving applications for mail-in ballots for the July and November 2020 elections, stating that the Court was confident that Respondents will comply.Under the Texas Election Code, qualified voters are eligible to vote by mail in only five specific circumstances, including if the voter has a "disability." At issue in this case was whether a voter's lack of immunity from COVID-19 and concern about contracting it at a polling place is a "disability" within the meaning of section 82.002. The Supreme Court held that a voter's lack of immunity to COVID-19 is not a "disability" as defined by the Election Code. Because Respondents assured the Court that they will fully discharge their duty to follow the law the Supreme Court concluded that issuing the writ of mandamus to compel them to do so was unwarranted. View "In re State of Texas" on Justia Law

Posted in: Election Law