Justia Texas Supreme Court Opinion Summaries

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

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