Justia Texas Supreme Court Opinion Summaries

An employee, Sharon Dunn, was injured while working as an emergency-department nurse for East Texas Medical Center Athens (ETMC Athens), a nonsubscriber to the Texas workers’ compensation program. Dunn alleged that an emergency medical technician (EMT), who was not employed by ETMC Athens, negligently pushed a stretcher into her, causing a serious back injury. Dunn initially sued the EMT and his employer, but those claims were dismissed due to her failure to timely serve an expert report as required by the Texas Medical Liability Act. Dunn then amended her pleadings to assert negligence claims against ETMC Athens.The trial court granted ETMC Athens's motion to designate the EMT and his employer as responsible third parties under the Texas proportionate-responsibility statute. However, eleven months later, Dunn moved to strike the designations, arguing that her suit was an action to collect workers’ compensation benefits, to which the proportionate-responsibility statute does not apply. The trial court granted Dunn’s motion, and the court of appeals denied ETMC Athens’s petition for mandamus relief.The Supreme Court of Texas reviewed the case and concluded that the trial court abused its discretion by striking the designations. The court held that the proportionate-responsibility statute applies because Dunn’s negligence claim against ETMC Athens is not an action to collect workers’ compensation benefits under the Workers’ Compensation Act. The court also held that the Act does not prohibit nonsubscribing employers from designating responsible third parties and that there was sufficient evidence of the third parties’ responsibility. Consequently, the Supreme Court of Texas conditionally granted ETMC Athens’s petition for mandamus relief, ordering the trial court to vacate its order striking the designations. View "IN RE EAST TEXAS MEDICAL CENTER ATHENS" on Justia Law

Tom and Becky Carlson filed a contested case against the Texas Comptroller under the Private Real Property Rights Preservation Act (PRPRPA), alleging that the Comptroller’s approval of a wind turbine project resulted in a taking of their property. The case was referred to the State Office of Administrative Hearings (SOAH), where the Administrative Law Judge (ALJ) dismissed it as untimely filed, stating that neither the Comptroller nor SOAH had jurisdiction. The Carlsons sought clarification from SOAH, which indicated that the case would return to the Comptroller for a final decision. However, the Comptroller later asserted that the ALJ’s order was final and appealable, leading to the Carlsons' mandamus petition.The Carlsons filed a mandamus petition directly in the Supreme Court of Texas, seeking to compel the Comptroller to issue a final order so they could appeal to district court. The State initially defended the Comptroller’s position that the ALJ’s order was final. However, after the Supreme Court requested clarification on the State’s unified position, the Comptroller issued a final decision, rendering the Carlsons' petition moot.The Supreme Court of Texas held that the Comptroller’s issuance of a final decision extinguished the dispute, making the mandamus petition moot. The Court dismissed the petition for lack of jurisdiction, as there was no longer a justiciable controversy between the parties. The Carlsons agreed with this outcome, as they would now receive the judicial review they sought. View "IN RE CARLSON" on Justia Law

Mara Lindsey was involved in a car accident where she was rear-ended by Carlos Pantoja, resulting in personal injuries. Lindsey sought compensation for her medical expenses and, after settling with Pantoja’s insurer for his policy limit of $50,000, she filed a claim with her own insurer, State Farm, under her underinsured motorist (UIM) policy. Dissatisfied with State Farm’s settlement offer of $689.58, Lindsey sued State Farm under the Uniform Declaratory Judgments Act (UDJA) for declarations regarding Pantoja’s liability, her damages, and her entitlement to UIM benefits. She also sued State Farm and its claims adjuster for Insurance Code violations, alleging bad faith in handling her claim.The trial court denied State Farm’s motions to abate the extracontractual claims and to quash the deposition notice of its corporate representative. The court of appeals denied State Farm’s mandamus petitions without substantive explanation. State Farm then petitioned the Supreme Court of Texas for mandamus relief.The Supreme Court of Texas held that the trial court abused its discretion by denying State Farm’s motions. The court ruled that extracontractual claims must be abated until the insured obtains a favorable judgment on the UIM coverage, as these claims are dependent on the right to receive UIM benefits. The court also held that discovery on extracontractual matters is improper before establishing entitlement to UIM benefits. Additionally, the court found that State Farm had demonstrated that the deposition of its corporate representative was not proportional to the needs of the case, given the lack of personal knowledge and the burden of the proposed discovery.The Supreme Court of Texas conditionally granted State Farm’s petition for writ of mandamus, ordering the trial court to vacate its previous orders and grant State Farm’s motions to abate the extracontractual claims and to quash the deposition notice. View "IN RE STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY" on Justia Law

A Colorado real estate investment trust sued a Texas hedge fund and its employees for damages caused by an allegedly defamatory article published under a pseudonym. The claims were dismissed in Colorado federal court for lack of personal jurisdiction. The trust then sued in Texas state court. The defendants moved to dismiss under the Texas Citizens Participation Act (TCPA) and for summary judgment based on collateral estoppel. The trial court granted both motions.The Court of Appeals for the Fifth District of Texas reversed the trial court's decision. It held that the trial court lacked authority to grant the TCPA motion after it was overruled by operation of law and that the defendants failed to conclusively establish that collateral estoppel barred the claims. The appellate court determined that the Colorado court's findings on personal jurisdiction did not preclude the Texas claims and that the addition of new defendants in Texas further demonstrated that the issues were not identical.The Supreme Court of Texas reviewed the case. It agreed with the appellate court that the defendants were not entitled to summary judgment on their collateral estoppel defense. However, it found that the appellate court erred in holding that the order granting the TCPA motion was void. The Supreme Court of Texas concluded that the trial court's error in granting the TCPA motion outside the statutory deadline was harmless because it occurred within the time frame in which the defendants could have appealed the denial by operation of law. The case was remanded to the appellate court to address the TCPA motion on its merits. View "FIRST SABREPOINT CAPITAL MANAGEMENT, L.P. v. FARMLAND PARTNERS INC." on Justia Law

A woman, acting as guardian for her elderly father, moved him out of the house he shared with his fourth wife and later filed for divorce on his behalf, citing that the couple had lived apart for more than three years. The trial court granted the divorce, and the wife appealed. The man died while the appeal was pending, and the Court of Appeals dismissed the appeal as moot but affirmed the divorce decree.The wife raised three issues before the Supreme Court of Texas: (1) the man's death did not moot her appeal, (2) Texas law does not permit a guardian to sue for divorce on her ward’s behalf, and (3) living apart is not a ground for divorce when neither spouse voluntarily lived apart from the other. The Supreme Court agreed that the man's death did not moot the appeal because whether the marriage ended by divorce or by death substantially affects the wife’s asserted property interests.The Supreme Court of Texas did not definitively decide whether Texas law permits a guardian to sue for divorce on behalf of a ward. However, it held that, to whatever extent the Texas Estates Code may allow a guardian to seek a divorce on her ward’s behalf, it requires the guardianship and divorce courts to find that permitting the divorce would promote the ward’s well-being and protect his best interests. Because neither court made that finding in this case and, due to the ward’s death, neither can do so now, the Supreme Court reversed the Court of Appeals’ judgment, vacated the divorce decree, and dismissed the suit. View "IN THE MATTER OF THE MARRIAGE OF BENAVIDES" on Justia Law

Barrie Myers was seriously injured in an automobile crash shortly after midnight on November 30, 2018. Nasar Khan, who had been drinking at Cadot Restaurant in Dallas, rear-ended Myers’s vehicle. Khan’s blood alcohol content (BAC) was 0.139, well above the legal limit. The record, however, leaves many facts about the evening unclear, including how much alcohol Khan consumed and how long he was at the restaurant and Jones’s home before the crash.The trial court granted summary judgment in favor of Cadot Restaurant, concluding that Myers produced no evidence to establish that it was apparent to Cadot that Khan was obviously intoxicated to the extent that he presented a clear danger when served. The Court of Appeals for the Fifth District of Texas reversed, holding that a fact issue existed based on Khan’s deposition concessions about his appearance and demeanor at Cadot.The Supreme Court of Texas reviewed the case and agreed with the trial court. The court held that the evidence presented by Myers required impermissible inferences upon inferences to establish how Khan may have appeared when served. The court emphasized that the Texas Dram Shop Act requires proof that it was apparent to the provider that the customer was obviously intoxicated to the extent that he presented a clear danger. The court found that the circumstantial evidence, including Khan’s BAC and expert testimony, was insufficient to establish this fact. The court also concluded that the trial court did not abuse its discretion in denying Myers’s motion for continuance. Consequently, the Supreme Court of Texas reversed the Court of Appeals’ judgment and reinstated the trial court’s summary judgment in favor of Cadot. View "Raoger Corp. v. Myers" on Justia Law

Save Our Springs Alliance, Inc. (SOS) challenged a final order by the Texas Commission on Environmental Quality (TCEQ) granting the City of Dripping Springs a permit to discharge treated wastewater into Onion Creek. The central issue was the interpretation of TCEQ’s “antidegradation” rules, specifically whether TCEQ should assess water quality degradation by evaluating the water body as a whole or by focusing on numeric changes in individual water-quality parameters. SOS argued for a strict parameter-by-parameter approach, claiming that any significant change in a single parameter, such as dissolved oxygen, should prevent permit approval.The Court of Appeals for the Eighth District of Texas upheld the permit’s issuance, finding that TCEQ’s practice of assessing overall water quality conformed to regulatory requirements. The court also rejected SOS’s argument that TCEQ’s final order was invalid for not including a “statement of the underlying facts” supporting its findings.The Supreme Court of Texas affirmed the Court of Appeals’ judgment. The court held that TCEQ’s whole-body approach to assessing water quality degradation was consistent with the regulatory language, which focuses on overall water quality rather than individual parameters. The court also found that substantial evidence supported TCEQ’s determination that the permitted discharge would not lower Onion Creek’s water quality by more than a de minimis extent. Additionally, the court rejected SOS’s argument that TCEQ’s final order was invalid for lacking specific underlying facts, noting that the order sufficiently informed the parties of the basis for TCEQ’s decision and complied with the relevant statutory requirements. View "Save Our Springs Alliance, Inc. v. Texas Commission on Environmental Quality" on Justia Law

In this case, the State charged an adult with capital murder, alleging he was sixteen at the time of the offense. The juvenile court found it was not practicable to proceed before the adult turned eighteen because the State lacked probable cause to arrest him at that time. The court of appeals reversed and dismissed the case, holding that probable cause existed to arrest him before he turned eighteen, thus the State failed to establish it was impracticable to proceed.The juvenile court granted the State’s motion to transfer the case to adult criminal court, combining elements of two statutory good cause alternatives. The court of appeals vacated the order and dismissed the case for want of jurisdiction, noting the juvenile court’s findings were difficult to decipher and lacked a “due diligence” finding required by one of the statutory alternatives. The court of appeals concluded that the State had sufficient evidence to establish probable cause before the respondent turned eighteen, and the reasons for delay were not beyond the State’s control.The Supreme Court of Texas reviewed the case and largely agreed with the dissenting justice from the court of appeals. The Court held that the development of probable cause alone does not determine whether it is “practicable to proceed” with a juvenile prosecution before a person reaches adulthood. Other reasons beyond the control of the State may support such a finding. The Court found that the juvenile court erred in conflating “practicable to proceed” with the existence of probable cause and remanded the case to the juvenile court for a new transfer hearing. The Supreme Court of Texas reversed the judgment of the court of appeals and remanded the case for further proceedings consistent with its opinion. View "IN THE MATTER OF J.J.T." on Justia Law

Kensington Title-Nevada, LLC, a Nevada-based real estate company, acquired property in Denton, Texas, which contained radioactive materials owned by US Radiopharmaceuticals, Inc. (USR). The Texas Department of State Health Services had denied USR’s application for a radioactive material license and ordered decommissioning of the materials. Kensington proposed a decommissioning plan, which the Department approved, and a licensed contractor began the cleanup. However, Kensington faced conflicting demands from the Department and local taxing entities, leading to a halt in decommissioning.The Department issued a notice of violation to Kensington for possessing radioactive material without a license and sought an $8,000 penalty. Kensington amended its pleading in an ongoing tax dispute to seek a declaratory judgment under Section 2001.038(a) of the Administrative Procedure Act, asserting that the licensing rule did not apply to it as it did not own or possess the radioactive material. The trial court denied the Department’s plea to the jurisdiction, but the Court of Appeals reversed, holding that Kensington failed to allege a proper rule-applicability challenge.The Supreme Court of Texas reviewed the case and held that Kensington had standing to seek a declaratory judgment under Section 2001.038(a). The Court found that Kensington’s allegations of interference with its legal rights due to the Department’s notice of violation were sufficient to establish standing. The Court also concluded that Kensington’s challenge to the applicability of the licensing rule was within the scope of the statute’s waiver of immunity. The Court reversed the Court of Appeals’ judgment and remanded the case to the trial court for further proceedings. View "KENSINGTON TITLE-NEVADA, LLC v. TEXAS DEPARTMENT OF STATE HEALTH SERVICES" on Justia Law

After Hurricane Harvey in 2017, the City of Houston amended its ordinances to increase elevation requirements for construction in floodplains. A developer, The Commons of Lake Houston, Ltd., sued the City, claiming the amendments caused a regulatory taking of its property under the Texas Constitution. The developer argued that the new requirements rendered a significant portion of its property undevelopable, leading to financial losses.The trial court denied the City’s plea to the jurisdiction, but the Court of Appeals for the First District of Texas reversed and dismissed the case. The appellate court held that the developer could not establish a valid takings claim because the City amended the ordinance as a valid exercise of its police power and to comply with the National Flood Insurance Program (NFIP) criteria.The Supreme Court of Texas reviewed the case and disagreed with the appellate court's reasoning. The Court held that a regulation could cause a compensable taking even if it results from a valid exercise of the government’s police power or is designed to comply with the NFIP. The Court also found that the developer’s claim was ripe for adjudication, as the City had effectively made it clear that the developer could not obtain the necessary permits under the new ordinance. Additionally, the Court determined that the developer had standing to assert its claim, as it possessed a vested interest in the property affected by the ordinance.The Supreme Court of Texas reversed the judgment of the Court of Appeals and remanded the case to the trial court for further proceedings to determine whether the amended ordinance caused a compensable taking under the Texas Constitution. View "THE COMMONS OF LAKE HOUSTON, LTD. v. CITY OF HOUSTON, TEXAS" on Justia Law