Justia Texas Supreme Court Opinion Summaries

In this case arising out of a construction contract dispute involving competing claims of breach between the owner and the contractor, the Supreme Court reversed in part the court of appeals' judgment affirming the portion of the trial court's judgment awarding damages to the owner but reversing as to the contractor, holding that the judgment awarding certain expenses to the owner could not stand.The jury found that both the owner and the contractor breached the contract and awarded damages as to both parties. At issue was whether the owner's entitlement to recover contract damages associated with a termination of the contractor for default hinged on strict compliance with the written-notice conditions precedent to such recovery, whether sufficient evidence supported the jury's finding of compliance, and whether a contractual provision governing consequential damages was liability waiver or a covenant not to sue. The Supreme Court held (1) when a contract mandates written notice, a writing is a necessary part of complying with contractual notice conditions, substantially or otherwise; (2) because the owner failed to provide the requisite written notices to be entitled to recover expenses associated with a termination for default, the judgment awarding them to the owner could not stand; and (3) the contract did not contain a covenant not to sue for consequential damages. View "James Construction Group, LLC v. Westlake Chemical Corp." on Justia Law

The Supreme Court reversed the judgment of the court of appeals dismissing Petitioner's appeal for lack of jurisdiction, holding that Petitioner's filing error did not deprive the court of appeals of subject matter jurisdiction.Petitioner brought multiple wrongful death and survival claims against several defendants. The trial court granted Respondents' motion for a take-nothing judgment. An ensuing severance transformed the interlocutory summary judgment into a final and appealable judgment, commencing the thirty-day period to file a notice of appeal. Petitioner then moved for a new trial. At issue was whether Petitioner's ensuing notice of appeal was timely, which depended on whether Petitioner's motion for new trial was effective. The court of appeals held that the motion for new trial was ineffective because Petitioner filed it under the wrong case number and dismissed the appeal for lack of jurisdiction. The Supreme Court reversed, holding (1) Petitioner's motion for new trial effectively extended the trial court's plenary power and, correspondingly, the appellate timelines; and (2) therefore, the appeal was timely. View "Mitschke v. Borromeo" on Justia Law

The Supreme Court reversed the judgment of the trial court affirming a verdict for the family of a teenager who committed suicide after seeking treatment for depression from her pediatric healthcare providers, holding that the testimony did not establish the necessary but-for causation required by precedent.The expert testimony at trial established negligence on the part of the teen's medical providers but did not establish that, but for the negligence, the teen would not have committed suicide. Plaintiffs sued their daughter's providers for negligence and gross negligence. The jury found that certain providers were liable, and the trial court awarded $1.285 million to Plaintiffs. The court of appeals affirmed. The Supreme Court reversed, holding that there was no evidence that the providers' care proximately caused the teen's suicide. View "Pediatrics Cool Care v. Thompson" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the trial court's grant of summary judgment for the current owners of certain property, holding that Elizabeth Mitchell's due process rights were violated in a 1999 suit in which the court entered a default judgment foreclosing a tax lien on Elizabeth's interest.After Elizabeth died in 2009, her heirs (Petitioners) brought suit to declare void the 1999 default judgment, alleging the judgment violated Elizabeth's constitutional right to procedural due process because Elizabeth was not properly served with notice of the underlying foreclosure suit. Respondents, the current owners of the property who purchased it at a tax sale or later acquired an interest in it, argued that the publicly recorded warranty deeds and county tax records could not be considered in this collateral attack. The trial court agreed and granted summary judgment for Respondents. The court of appeals affirmed. The Supreme Court reversed, holding (1) information available in relevant public records can be considered in a collateral attack on a judgment that alleges constitutional due process violations; and (2) Petitioners established that Elizabeth was not properly served in the 1999 suit, and therefore, the court in the tax foreclosure suit did not acquire personal jurisdiction over Elizabeth. View "Mitchell v. MAP Resources, Inc." on Justia Law

In this dispute over a family ranch the Supreme Court affirmed in part and reversed in part the judgment of the court of appeals reversing in part the district court's rejection of Plaintiffs' claims on summary judgment, holding that Kenneth Berry's claims were properly rejected by the district court but that Chelsea Berry's claims should have been allowed to proceed.Kenneth and his daughter Chelsea filed this suit alleging that Defendants did not pay for the use of the ranch and that a lease between the parties was impermissibly long. The district court granted summary judgment for Defendants on all claims. The court of appeals affirmed the dismissal of Chelsea's claims and some of Kenneth's claims but reversed as to Kenneth on a statute of limitations issue. The Supreme Court reversed in part, holding that the district court (1) properly disposed of all of Kenneth's claims; but (2) erred in dismissing Chelsea's claims. View "Berry v. Berry" on Justia Law

In this consolidated appeal involving unrelated respondents who were acquitted of driving while intoxicated (DWI), the Supreme Court affirmed the judgments of the lower courts, holding that the exception to expunction did not apply in this case.Both respondents sought expunction of the records relating to their arrests, and both had a previous DWI conviction from at least three years before the arrest that led to acquittal. Separate trial courts ordered expunction of each respondent's records. The court of appeals affirmed. The Supreme Court affirmed, holding that both respondents established their entitlement to expunction and that no exception applied. View "Ex parte K.T." on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the judgment of the trial court against Landlord and in favor of the City of Baytown in this dispute over unpaid utility bills, holding that Landlord's challenge to the City's enforcement action failed to show the intentional taking or damage for public use necessary to establish a constitutional right to compensation.In this action, Landlord alleging that the City's withholding of utility service to collect payment resulted in the loss of a tenant and the disrepair of his property and was a taking in violation of the state or federal constitution. The trial court concluded that Landlord did not establish an intentional taking of private property for public use. The court of appeals reversed. The Supreme Court reversed, holding that the City's utility enforcement actions did not establish a regulatory taking of private property as a matter of law. View "City of Baytown v. Schrock" on Justia Law

The Supreme Court denied a petition for writ of mandamus sought by Relators for relief from trial court orders granting Christina Broussard's motions to quash certain discovery subpoenas in this case brought by Broussard against Relators for personal injuries and economic losses following a rear-end collision, holding that the discovery requests sought relevant information.The subpoenas sought post-accident medical-billing information from Broussard's medical providers and third-party production of Broussard's pre-accident medical, education, employment, and insurance records. Relators argued that the requested discovery was relevant to the issue of damages causally attributable to the accident. The trial court quashed the discovery subpoenas. The Supreme Court denied mandamus relief without prejudice to Relators' seeking relief, if necessary, after the trial court has had an opportunity to reconsider its rulings, holding that the trial court should reconsider its orders in light of this Court's opinion in In re K&L Auto Crushers, LLC, 627 S.W.3d 239 (Tex. 2021). View "In re Central Oregon Truck Co., Inc." on Justia Law

In this oil and gas case, the Supreme Court reversed the judgment of the court of appeals reversing the trial court's summary judgment, holding that a fact issue remained on Plaintiffs' claim for breach of the lease and that Plaintiffs' argument was not barred by res judicata but that the court of appeals erred by reversing a take-nothing summary judgment as to Plaintiffs' tort and statutory claims.At issue was the meaning and application of an express covenant to protect against drainage that appeared in a lease addendum that expressly limited the location of wells that may trigger Defendant-Lessee's obligation to protect against drainage but did not directly address the location of wells that may cause drainage. Plaintiffs-Lessors argued that the covenant allowed for separate triggering and draining wells and that Defendant breached the covenant by failing to protect against drainage from a non-triggering well. In response, Defendant argued that it had a duty to protect only against drainage from the limited class of triggering wells. The Supreme Court held (1) the addendum was ambiguous because both interpretations of the covenant were reasonable; (2) the court of appeals improperly reversed the trial court's take-nothing summary judgment on Plaintiffs' tort and statutory claims; and (3) remand was required for further proceedings on Plaintiffs' claim for breach of the lease. View "Rosetta Resources Operating, LP v. Martin" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals that the attorney-immunity defense was inapplicable to federal wiretap claims but reversed and rendered judgment for the defendant-attorney on Plaintiffs' state wiretap claims, holding that the attorney-immunity defense was inapplicable to the federal wiretap claims but did attach to the state wiretap claims.Plaintiffs brought this private party civil suit asserting that Defendant and others had violated the federal and Texas wiretap statutes by using and disclosing illegally intercepted electronic communications. Defendant moved for summary judgment, arguing that she was immune from liability as a matter of law because Plaintiffs' claims all stemmed from her role as an attorney in a modification proceeding. The trial court agreed and rendered summary judgment for Defendant. The court of appeals reversed. The Supreme Court affirmed in part and reversed in part, holding (1) Defendant was entitled to summary judgment on the state wiretapping claims; but (2) Defendant was not entitled to summary judgment on the claims under the federal wiretap statute because this Court is not convinced that federal courts would apply Texas's common-law attorney-immunity defense to that statute. View "Taylor v. Tolbert" on Justia Law