Justia Texas Supreme Court Opinion Summaries

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The Supreme Court affirmed in part and reversed in part the judgment of the court of appeals affirming the orders that held that a county attorney lacked authority to pursue certain claims on the state's behalf and that sanctioned him personally and individually for pursuing the claims without such authority, holding that the court should have accepted the attorney's appeal from the sanctions order.In affirming the orders at issue, the court of appeals agreed with the lower court that the attorney lacked authority and held that he failed to perfect an appeal on his own behalf. The Supreme Court reversed in part, holding that the court of appeals (1) correctly held that the attorney lacked authority; but (2) should have accepted the attorney's appeal for the order of sanctions or permitted him to amend the notices of appeal. View "State ex rel. Durden v. Shahan" on Justia Law

Posted in: Legal Ethics
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The Supreme Court reversed the decision of the court of appeals reversing the decision of the trial court granting summary judgment in favor of the company alleged to be a deceased worker's employer and dismissing this vicarious liability case, holding that the court of appeals erred.An oilfield worker was involved in a fatal accident as he was driving to the oilfield drilling site after completing personal errands. At issue was whether the court of appeals erroneously relied upon the "special mission" exception in declining to apply the general rule that an employer is not vicariously liable for negligence arising from employee travel to and from work. The Supreme Court reversed, holding that a personal trip for groceries does not fall within the special mission exception to the general rule that an employer is not vicariously liable for an employee's negligent acts while the employee travels to and from work. View "Cameron International Corp. v. Martinez" on Justia Law

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The Supreme Court granted Petitioner's petition for review of the decision of the court of appeals affirming the decision of the trial court granting the City of Austin's plea to the jurisdiction and dismissing this case brought by Plaintiff alleging that the City provided taxpayer money to abortion-assistance organizations in violation of Texas law, holding that the case must be remanded.The trial court granted the City's plea to the jurisdiction without explaining its reasons and dismissed with prejudice Petitioner's claim that the City's budget violated Texas law and dismissed with prejudice Petitioner's claim that the City's 2019 budget violated the Gift Clause. The court of appeals affirmed, relying on the Supreme Court's holding in Roe to conclude that Petitioner's claim could not proceed. Petitioner petitioned for review. After briefing was complete, the United States Supreme Court issued its opinion in Dobbs v. Jackson Women's Health Organization, 142 S. Ct. 2228 (2022). The Supreme Court granted Petitioner's petition for review without regard to the merits and vacated the judgments below, holding that, because Dobbs overruled Roe, remand was required for consideration of the effect this change in the law and any intervening factual developments on Petitioner's claims. View "Zimmerman v. City of Austin" on Justia Law

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In this dispute over ownership of some ranchland the Supreme Court affirmed the judgment of the court of appeals ruling that a grantor conveys an expectancy interest only through a clear manifestation of the grantor's intent to do so, holding that the court of appeals did not err.Father devised his estate, including Cottonwood Ranch, to Widow for life with the remainder upon her death to his children, including Son. Father granted Widow power to sell estate property and to redirect a child's remainder interest to others. Widow, a co-owner of the ranch, later conveyed her separate interest in the ranch to Son and daughter. Thereafter, while Widow was still living, Son conveyed his "right, title and interest in and to" the ranch to his daughters. At issue was whether Son gifted a remainder interest in Father's estate property when he conveyed his present interest in the same property without expressly reserving any remainder interest. Applying the rule set forth in Clark v. Gauntt, 161 S.W.2d 270 (Tex. [Comm'n Op.] 1942), the Supreme Court held that Son did not convey his remainder interest in the estate property. View "Jordan v. Parker" on Justia Law

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In this personal injury case, the Supreme Court held that a governmental defendant retains its immunity from suit as to a claim that exceeds the applicable damages cap,Plaintiff was crossing the street when he was hit by a bus driven by an employee of Defendant, the Gulf Coast Center, and sued Defendant for his resulting injuries. Defendant answered, claiming that it was a governmental unit, that it was protected from suit and liability by governmental immunity, and that its liability, if any, was limited by the Texas Tort Claims Act. The jury found Defendant negligent and awarded Plaintiff $216,000. Defendant appealed, arguing that the Act capped its liability at $100,000. The court of appeals affirmed. The Supreme Court reversed, holding that the Act waives a governmental unit's immunity from suit only to the extent the act waives it immunity from liability, and therefore, courts lack jurisdiction to render a judgment that exceeds the applicable damages cap under Tex. Civ. Proc. & Rem. Code 101.023. View "Gulf Coast Center v. Curry" on Justia Law

Posted in: Personal Injury
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The Supreme Court conditionally granted mandamus relief in this case concerning a premarital agreement to resolve disputes by binding arbitration under religious law, holding that the trial court was statutorily required to hear and determine Wife's challenges to the agreement's validity and enforceability before referring the parties' disputes to arbitration.When the parties in this case married they signed an "Islamic Pre-Nuptial Agreement" providing that "[a]ny conflict which may arise between the husband and the wife will be resolved according to the Qur'an, Sunnah, and Islamic Law in a Muslim court, or in [its] absence by a Fiqh Panel." When Wife sued for divorce, Husband moved to enforce the agreement. After a hearing on whether the reference to Islamic law was sufficiently ambiguous to render the agreement unenforceable the trial court ordered the parties to arbitrate under the agreement. Wife moved for mandamus relief. The Supreme Court conditionally granted relief, holding that the trial court erred in compelling the parties to arbitrate. View "In re Mariam Ayad" on Justia Law

Posted in: Contracts, Family Law
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The Supreme Court conditionally granted a writ of mandamus in this action arising out of a chemical release at a plant, holding that mandamus is granted to direct the trial court to vacate its orders requiring Kuraray American, Inc. to produce cell-phone data from the employer-issued phones of five employees.In the order at issue, the trial court ordered production of cell-phone data from two of the five employees for the six-week period before the chemical release. As to the remaining employees, the trial court ordered production of cell phone data for the four-month period before the release. The Supreme Court conditionally granted a writ of mandamus and directed the trial court to vacate its orders requiring production of all five employees' cell-phone data, holding that the orders required production of information as to which relevance had not been established and thus were impermissibly overbroad. View "In re Kuraray America, Inc." on Justia Law

Posted in: Civil Procedure
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The Supreme Court conditionally granted a writ of mandamus sought by real parties in interest (the Paus) in this action brought against Relators (collectively, Auburn Creek) seeking $33 million in damages allegedly caused by carbon-monoxide exposure in a dwelling the Paus leased from Auburn Creek, holding that the trial court clearly abused its discretion in denying Auburn Creek's motion to compel.Auburn Creek filed a motion to compel a neuropsychological exam for each of the Pau family members. The trial court denied the motion with prejudice on the grounds that the scope of the exams was not sufficiently circumscribed and subsequently denied Auburn Creek's request for mandamus relief. The Supreme Court conditionally granted relief, holding that the trial court abused its discretion by concluding that Auburn Creek had not shown good cause for the exams. View "In re Auburn Creek Limited Partnership" on Justia Law

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The Supreme Court reversed in part the judgment below and remanded this case for further proceedings that will allow the district court to render a judgment that complies with the periodic-payments statute, holding that the district court erred in how it structured the periodic payments in this case.A.M.A. was diagnosed with cerebral palsy after being deprived of oxygen during extended periods during his mother's labor. A jury awarded future healthcare expenses in the amount of almost $10,000,000. The trial judge ordered the award structured into periodic payments. The court of appeals affirmed. The Supreme Court reversed in part, holding that there was nothing in the evidence that justified the way the trial court ordered the periodic payments to be structured. View "Columbia Valley Healthcare System, L.P. v. A.M.A." on Justia Law

Posted in: Personal Injury
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In these consolidated appeals the Supreme Court denied Respondents' request to withdraw the Chief Justice's certification letter and dismiss the underlying petitions as improvidently granted, holding that the Governor's appointment of two substitute justices to participate in the determination of these cases did not violate due process or due course of law protections.After two of the Supreme Court's nine justices voluntarily recused themselves from the case, the Chief Justice requested that the Governor appoint two qualified justices or judges to participate in the Court's determination of these appeals. Respondents objected, arguing that allowing the Governor to appoint justices would create due process and ethical problems where the State was not a party. The Supreme Court denied Respondents' requests to dismiss the petitions as improvidently granted, holding (1) there was no serious risk of actual bias under Caperton v. A.T. Massey Coal Co., 556 U.S. 868 (2009); and (2) the Governor's appointment of the two substitute justices did not taint the commissioned justices with the appearance of partiality or impropriety under the Texas ethical rules. View "State v. Audi Aktiengesellschaft" on Justia Law