Justia Texas Supreme Court Opinion Summaries

The Supreme Court held that the application the Fair Practices of Equipment Manufacturers, Distributors, Wholesalers, and Dealers Act, Tex. Bus. & Com. Code 57.001-.402, in this case did not violate the constitutional prohibition against retroactive laws in Tex. Const. art. I, 16.In the 1990s, Fire Protection Service, Inc. (FPS), orally agreed to be an authorized dealer and servicer of the life rafts manufactured by Survitec Survival Products, Inc. Nearly six years after the promulgation of the Act, which prohibits a supplier from terminating a dealer agreement without good cause, Survitec notified FPS that it was terminating their relationship. FPS sued for a violation of the Act. The district court entered judgment for Survitec. On appeal, the Fifth Circuit certified a question to the Supreme Court. The Supreme Court answered that the application of the Act to the parties' agreement does not violate the retroactivity clause in article I, section 16. View "Fire Protection Service, Inc. v. Survitec Survival Products, Inc." on Justia Law

The Supreme Court held that, absent a clear abuse of discretion, governmental immunity protects a zoning commission's determination that a proposed subdivision conforms with applicable law.After the City of Georgetown's Planning and Zoning Commission approved a preliminary plat for a new 89-home subdivision neighboring Escalera Ranch, a subdivision to the north the Escalera Ranch Owners' Association sued the Commission members, asserting that their approval of the plat was a clear abuse of discretion. The trial court granted the Commissioners' plea to the jurisdiction, concluding that the Association lacked standing to sue. The court of appeals reversed. The Supreme Court reversed, holding that the Commissioners adhered to their duty in determining that the preliminary plat conformed to the applicable standards. View "Schroeder v. Escalera Ranch Owners' Ass'n" on Justia Law

The Supreme Court held that the Texas Medical Board is not required by federal law or permitted by Texas law to merely revise an initial report of a temporary sanction, rather than void it, when the Board later finds that the allegations have not been proved.Federal and State law require the Board to report a disciplinary action against a physician to the National Practitioner Data Bank to restrict the ability of incompetent physicians to move from state to state. The Board issued a temporary sanction against Dr. Robert Wayne Van Boven while it investigated misconduct allegations. The Board then issued a final order concluding that Van Boven was not subject to sanctions. Van Bovcen brought this ultra vires action against Board officials directing them to file a Void Report with the Data Bank, which would remove the initial report against him and a subsequent revision-to-action report from disclosure. The trial court denied Defendants' plea to the jurisdiction asserting sovereign immunity. The court of appeals reversed. The Supreme Court reversed, holding that the Board officials' actions in this case were ultra vires and that the officials were not immune from Van Boven's claims. View "Van Boven v. Freshour" on Justia Law

The Supreme Court reversed the judgment of the court of appeals dismissing a pending appeal as moot without resolving a jurisdictional issue, holding that remand was required.Defendants, a Taiwanese company and its CEO who were sued under various tort theories, specially appeared and challenged personal jurisdiction. The trial court denied the special appearances, and Defendants filed an interlocutory appeal. The trial court then rendered final judgment against Defendants. When the deadline for filing an appeal had expired, Plaintiff moved to dismiss the interlocutory appeal. The court of appeals granted the motion, holding that, following rendition of final judgment, the jurisdictional issue could only be challenged by filing a separate notice of appeal. The Supreme Court reversed, holding that a second notice of appeal from the final judgment was unnecessary for the appellate court to maintain its pre-existing jurisdiction over the still-live jurisdictional dispute. View "Chen v. Razberi Technologies, Inc." on Justia Law

In this eminent domain dispute, the Supreme Court affirmed in part and reversed in part the decision of the court of appeals affirming in part and reversing in part the trial court's judgment in favor of a pipeline company, holding that remand was required for a new trial to determine the market value of the property taken.A landowner challenged the pipeline company's right to condemn, arguing that the transport of polymer-grade propylene did not the pipeline company common-carrier status. After excluding the landowner's evidence of sales of other pipeline easements the trial court found in favor of the pipeline company. The court of appeals reversed in part, holding that whether the pipeline served a public use presented a fact question for a jury to resolve and that the trial court erred in excluding the landowner's testimony about easement sales. The Supreme Court reversed in part, holding (1) Tex. Bus. Org. Code 2.105 grants common-carrier eminent domain authority for the construction and use of a polymer-grade propylene pipeline; (2) the company demonstrated that its pipeline served a public use, and that determination is a legal one; and (3) a property owner may testify to sales of pipeline easements across the property made to other pipeline carriers. View "Hlavinka v. HSC Pipeline Partnership, LLC" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the order of the trial court denying the motion for summary judgment filed by the City of Fort Worth in this case brought under the Texas Whistleblower Act, holding that Plaintiffs failed to present evidence that they reported a violation of law under the Act.Plaintiffs, two veteran law enforcement officers with the Fort Worth Police Department, brought this action alleging that they were unlawfully disciplined for making a "good faith report of a violation of law" regarding another officer's conduct. The City filed motion for summary judgment, arguing that Plaintiffs failed to allege jurisdictional facts necessary to show a waiver of sovereign immunity. The trial court denied the motion, and the court of appeals affirmed. The Supreme Court reversed, holding (1) Plaintiffs failed to raise a genuine issue of material fact as to whether they reported a violation of law under the Whistleblower Act; and (2) therefore, the Act did not waive the City's immunity from suit. View "City of Fort Worth v. Pridgen" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the judgment of the trial court terminating Father's parental rights to his child and remanded the case for a new trial, holding that it could not be discerned whether the jury terminated Father's rights on an invalid ground.The jury in this case ultimately found by clear and convincing evidence that both parents' rights to their child should be terminated, and the trial court rendered a final order of termination. The court of appeals affirmed as to both parents. Father appealed. The Supreme Court reversed, holding (1) the jury reasonably could have formed a firm belief or conviction that Father failed to maintain a safe and stable home environment as required by his service plan; (2) legally sufficient evidence supported the jury's best-interest finding; but (3) the trial court erred in submitting to the jury an invalid ground for termination of Father's rights, and it could not be determined whether the jury based its verdict on an improperly submitted termination ground. View "In re J.W." on Justia Law

The Supreme Court held that the Town of Westlake, a general-law municipality in which Builder Recovery Services, LLC (BRS), which hauled trash away from construction sites, operated, lacked the authority to impose a percentage-of-revenue license fee on companies like BRS.The Town enacted an ordinance that required trash haulers like BRS to obtain a license to operate in the Town. After the ordinance was adopted the Town cited BRS for operating without a lawsuit in violation of the ordinance. BRS brought this suitm, arguing that BRS lacked statutory authority to require BRS to obtain the license. The district court rejected most of BRS's arguments, and the court of appeals affirmed the portions of the judgment in favor of the Town. The Supreme Court reversed, holding that the Town of Westlake lacked authority as a general-law municipality to impose a percentage-of-revenue licensing fee on construction trash-hauling companies like BRS. View "Builder Recovery Services, LLC v. Town of Westlake" on Justia Law

The Supreme Court held that the Texas Commission on Environmental Quality's (TCEQ) general jurisdiction over water and water rights, including the issuance of water rights permits and water rights adjudication, does not include the authority to adjudicate conflicting claims to ownership of surface-water rights.Plaintiff brought this complaint seeking declarations that it was the sole owner of certain surface-water rights. Defendant filed a motion to dismiss the claims for lack of subject-matter jurisdiction, arguing that TCEQ has exclusive original jurisdiction to determine water-ownership rights. The trial court granted the motion to dismiss and the court of appeals affirmed. The Supreme Court reversed, holding that TCEQ lacks jurisdiction to decide conflicting claims of ownership to surface-water rights and that the adjudication of such claims is for the courts. View "Pape Partners, Ltd. v. DRR Family Properties LP" on Justia Law

The Supreme Court reversed the judgment of the court of appeals concluding that the "procuring-cause doctrine" did not apply to the facts of this case, holding that the procuring-cause doctrine applied to the parties' contractual relationship.If a seller agrees to pay sales commissions to a broker or other agent and their contract says nothing more than that commissions will be paid for sales, Texas law applies a default rule called the procuring-cause doctrine. When the seller refused to pay the broker in this case commissions on sales that were finalized after his termination, the broker sued the seller for breach of contract. The jury found for the broker. The court of appeals affirmed. The Supreme Court reversed and remanded the case for further proceedings, holding that the procuring-cause doctrine applied to the contractual relationship in this case. View "Pesthuis v. Baylor Miraca Genetics Laboratories, LLC" on Justia Law