Justia Texas Supreme Court Opinion Summaries

A group of workers was injured in a workplace accident at a South Texas refinery when a fire-suppression system, supplied and programmed by Scallon Controls, Inc., unexpectedly discharged after losing power. The workers sued S&B Engineers & Constructors, Ltd. and Sunoco Logistics Partners, the companies responsible for the project. S&B and Sunoco then brought third-party claims against Scallon, alleging breach of contract and seeking indemnification under their agreement, which included a proportional indemnity provision. Following four years of litigation, S&B and Sunoco settled with the injured workers, fully resolving the tort claims. S&B and its insurer, Zurich American Insurance Company, subsequently sought to recover from Scallon a proportional share of the settlement, corresponding to Scallon’s alleged share of fault.The trial court granted summary judgment for Scallon, and the Court of Appeals for the Ninth District of Texas affirmed, relying on prior Supreme Court of Texas decisions, notably Beech Aircraft Corp. v. Jinkins and Ethyl Corp. v. Daniel Construction Co. The appellate court held that S&B and Zurich could not maintain an indemnity claim after settling, and that Zurich’s claim was time-barred.The Supreme Court of Texas reversed, holding that neither Jinkins nor Ethyl precludes enforcement of a freely negotiated, proportional indemnification agreement after settlement. The Court clarified that such contracts are distinct from common law or statutory contribution rights and that parties may contract for comparative indemnity, so long as the contract does not require indemnification for the indemnitee’s own negligence unless stated with specific language. The Court also held that Zurich’s claim was timely, as the limitations period began to run at settlement. The case was remanded to the trial court to determine whether S&B and Zurich can establish Scallon’s proportional liability and the reasonableness of the settlement. View "S&B ENGINEERS & CONSTRUCTORS, LTD. v. SCALLON CONTROLS, INC." on Justia Law

Equinor contracted with Lindale to supply water for hydraulic fracturing operations in North Dakota. The agreement established that Lindale would build a pipeline to deliver water, financed by Equinor’s predecessor, who would then own the pipeline. In exchange, Lindale would serve as the exclusive supplier and pumper of water “on the Pipeline,” at below-market rates. Years later, after Equinor acquired its predecessor, technological advances enabled water delivery via lay-flat hoses, a method cheaper than using the pipeline. Equinor began purchasing water from other suppliers using this new method, rather than from Lindale.Lindale sued Equinor for breach of contract in the District Court, arguing that the exclusivity clause gave Lindale the exclusive right to supply water for all of Equinor’s fracking operations. The district court found the relevant contract provision ambiguous and submitted its interpretation to a jury. The jury found for Lindale and awarded $26 million in damages. The Texas Court of Appeals for the First District affirmed, concluding that Equinor had breached the contract and that the damages award was not excessive.The Supreme Court of Texas reviewed the case and determined that the contract was unambiguous. The court interpreted the exclusivity clause to apply solely to water supplied “on the Pipeline,” as defined by the contract, and not to all water delivered to Equinor’s wells by other means. As a result, Equinor’s purchase of water from other suppliers for wells not “on the Pipeline” did not breach the contract. The court reversed the judgment of the court of appeals and rendered judgment for Equinor, holding that there was no breach as a matter of law. View "EQUINOR ENERGY LP v. LINDALE PIPELINE, LLC" on Justia Law

A Texas-based company sold bunker fuel to primarily foreign-registered vessels at Texas ports, transferring possession and control of the fuel in Texas. The company initially paid franchise taxes on these sales, but later sought a refund, arguing that these transactions should not be attributed to Texas for franchise-tax purposes because the fuel was not used, sold, or consumed in Texas. The company contended that, under the relevant statute, sales should be sourced to the buyer’s ultimate destination or place of use, not merely the location where possession was transferred.After the Texas Comptroller denied the refund, the company exhausted administrative remedies and filed suit, also challenging the validity of regulations that sourced sales to Texas based on the point of delivery to the buyer. Both parties filed motions for summary judgment, focusing on whether the statutory phrase “delivered or shipped to a buyer in this state” refers to the place where the buyer takes delivery or to the location where the buyer uses or consumes the goods. The trial court ruled in favor of the Comptroller, upholding the regulations. On interlocutory appeal, the Court of Appeals for the Third District of Texas affirmed, finding the statute unambiguously sources sales based on where the buyer receives the property.The Supreme Court of Texas reviewed the case to resolve the statutory interpretation. The Court held that the statute sources receipts from sales of tangible personal property to Texas if the seller transfers possession and control to the buyer at a location in Texas, regardless of where the buyer ultimately uses or consumes the goods. The Court found that the Comptroller’s rules were consistent with this interpretation and thus valid. The judgment of the court of appeals was affirmed and the case remanded for further proceedings. View "NUSTAR ENERGY, L.P. v. HANCOCK" on Justia Law

In 1951, a deed was executed conveying an undivided 1/128 interest in oil, gas, and other minerals in certain Reeves County land. For nearly seventy years, the grantees and their successors received fixed 1/128 royalty payments without dispute. In 2020, a successor grantee, Johnson, asserted a different interpretation, claiming the deed provided a floating 1/16 nonparticipating royalty interest rather than the fixed 1/128 royalty everyone had understood and paid for decades.The 143rd District Court in Reeves County denied Johnson’s motion for summary judgment and granted summary judgment in favor of the Cliftons and other parties, confirming that the deed conveyed a fixed 1/128 royalty interest. Johnson appealed to the Court of Appeals for the Eighth District of Texas, which relied heavily on Van Dyke v. Navigator Group, 668 S.W.3d 353 (Tex. 2023). The appellate court applied the “double-fraction” presumption from Van Dyke, concluding that the deed conveyed a floating 1/16 royalty and reversed the trial court’s judgment. It also declined to remand the case to consider the presumed-grant doctrine, holding the Cliftons had forfeited that argument.The Supreme Court of Texas reviewed the case. It held that while the Van Dyke double-fraction presumption applied, the plain language of the deed rebutted the presumption, demonstrating that “1/8” was used for its ordinary numerical value, not as a term of art. The Court concluded the deed conveyed a fixed 1/128 royalty interest, not a floating 1/16 royalty. The Court reversed the appellate court’s judgment and reinstated the trial court’s summary judgment. The Court did not reach the presumed-grant doctrine issue, as its textual interpretation of the deed resolved the dispute. View "Clifton v. Johnson" on Justia Law

Cockrell Investment Partners, L.P., owns a pecan orchard in Pecos County, Texas, and relies on several wells to irrigate its trees using water from the Edwards–Trinity Aquifer. Its neighbor, Fort Stockton Holdings, L.P. (FSH), historically used water from the same aquifer for agricultural purposes and later started selling it to nearby cities. FSH sought to significantly increase its permitted water usage, leading Cockrell to object due to concerns about the aquifer’s finite supply. FSH pursued several permit applications and amendments, some of which involved Republic Water Company of Texas, LLC, and ultimately resulted in settlement agreements that altered FSH’s permit terms. Cockrell attempted to participate as a party in administrative proceedings regarding these permit applications but was denied party status by the Middle Pecos Groundwater Conservation District.The district court in one instance granted the District’s plea to the jurisdiction, and in another instance granted summary judgment in favor of the District after denying its plea to the jurisdiction. Cockrell appealed both decisions to the Court of Appeals for the Eighth District of Texas. The appellate court affirmed the lower court rulings, determining that Cockrell had not exhausted its administrative remedies because it filed suit before waiting the required 90 days after submitting reconsideration requests, as prescribed by Section 36.412 of the Texas Water Code.The Supreme Court of Texas reviewed both consolidated cases. It held that the 90-day exhaustion requirement applies only to permit applicants or parties to the administrative proceeding, which Cockrell was not, since it was denied party status. The Court concluded that Cockrell met all statutory requirements for judicial review under Section 36.251 of the Water Code and properly exhausted its administrative remedies according to local Rule 4.9, which required only a 45-day waiting period. The Court reversed the judgments of the court of appeals and remanded the cases for further consideration. View "COCKRELL INVESTMENT PARTNERS, L.P. v. MIDDLE PECOS GROUNDWATER CONSERVATION DISTRICT" on Justia Law

In 2019, a tornado struck the home of the insured homeowners, causing significant property damage. The homeowners held a policy issued by their insurer, which included an $87,156 deductible for losses caused by “Windstorm or Hail.” The policy did not define “windstorm.” The insurer applied this deductible to the homeowners’ claim, asserting that the tornado damage was subject to the windstorm deductible. The homeowners disputed this, arguing that a tornado is not a “windstorm” as commonly understood and that the deductible should not apply.The dispute led to litigation in the 68th District Court of Dallas County, where both parties filed motions for summary judgment based on the interpretation of the term “windstorm.” The trial court ruled for the insurer, finding that a tornado qualifies as a windstorm and applying the deductible. On appeal, the Court of Appeals for the Fifth District of Texas reversed, holding that “windstorm” was ambiguous in the policy context and could reasonably be read to exclude tornadoes. The appellate court rendered judgment for the homeowners, concluding that the ambiguity must be resolved in their favor.The Supreme Court of Texas reviewed the case and reversed the appellate court’s decision. The Supreme Court held that, when undefined in a homeowners insurance policy, the ordinary meaning of “windstorm” unambiguously includes a tornado. The Court examined dictionary definitions, statutory usage, and relevant case law, finding no persuasive authority that would exclude tornadoes from the scope of “windstorm.” Accordingly, the Supreme Court reinstated the trial court’s summary judgment in favor of the insurer, holding that the homeowners’ claim was subject to the policy’s windstorm deductible. View "PRIVILEGE UNDERWRITERS RECIPROCAL EXCHANGE v. MANKOFF" on Justia Law

A divorced couple’s agreed decree required them to sell community property, including their marital home, and divide the proceeds equally. The decree further required each party to deliver certain personal property to a receiver and specified that if either failed to deliver or damaged property, the fair market value of the missing or damaged items would be assessed against that party and “accounted for” out of the proceeds from the sale of the marital home. After the divorce, the wife alleged that the husband had damaged and failed to deliver certain property. The trial court found numerous violations, but rather than determining the specific value of the loss, it awarded the wife all proceeds from the sale of the marital home.The trial court, a district court in Texas, conducted hearings and ultimately ordered the entirety of the marital home’s sale proceeds be given to the wife, along with attorney’s fees and costs, without making findings about the fair market value of the alleged losses. The husband appealed, contending that the trial court had exceeded its jurisdiction by impermissibly modifying the substantive property division in the decree. The Twelfth Court of Appeals agreed, holding that the trial court’s order effectively redivided property in violation of Texas Family Code Section 9.007, and vacated the order, dismissing the case for lack of jurisdiction.Upon review, the Supreme Court of Texas held that the trial court retained jurisdiction to enforce the decree and award damages for breach, but it erred by reallocating all proceeds from the marital home without evidence of actual damages. The high court reversed the appellate court’s decision, clarified that the trial court’s error did not deprive it of enforcement jurisdiction, and remanded the matter for further proceedings to determine actual damages as required by the decree and statute. View "MORRISON v. MORRISON" on Justia Law

Following Hurricane Laura, a Texas-based company, Top Notch Movers, provided moving services in Alabama and Louisiana to Shamrock Enterprises, an Alabama-based LLC. Top Notch sent a demand letter to Shamrock seeking payment for over $170,000 in unpaid invoices. Subsequently, Top Notch filed suit in Texas for nonpayment, listing Shamrock’s principal office as a Foley, Alabama address and seeking substituted service via the Texas Secretary of State under section 5.251(1)(A) of the Texas Business Organizations Code. The Secretary of State attempted to forward process to the Foley address, but the mailing was returned as undeliverable. Shamrock did not appear, and Top Notch obtained a default judgment, which was also mailed to the same address and returned.Shamrock later initiated a restricted appeal, arguing that service of process was improper. The Court of Appeals for the Thirteenth District of Texas affirmed the default judgment, finding that Shamrock was amenable to substituted service under the cited statute and that the Secretary of State’s Whitney certificate constituted irrebuttable proof of proper service.The Supreme Court of Texas reviewed the case and determined that even if Shamrock was subject to substituted service under section 5.251(1)(A), the record did not show that process was forwarded to the statutorily required address—Shamrock’s “most recent address . . . on file with the secretary of state.” The court clarified that a Whitney certificate only proves that process was sent to the address provided, not that the statutory requirements were met, and strict compliance is necessary for a valid default judgment. Therefore, the Supreme Court of Texas reversed the judgment of the Court of Appeals, vacated the default judgment, and remanded the case to the trial court for further proceedings. View "SHAMROCK ENTERPRISES, LLC v. TOP NOTCH MOVERS, LLC" on Justia Law

A candidate for Justice of the Supreme Court sought to participate in the Texas Republican primary by submitting a ballot application to the party chair. The application was rejected as deficient, specifically due to concerns about the validity and sufficiency of the submitted signatures. The candidate disputed the rejection, arguing both that his original application met requirements and that he cured any alleged defects by submitting an amended application after the statutory deadline. The timing of the submissions was central: the original application was filed just hours before the deadline, and the amended materials were submitted several days after the deadline had passed.After the application was rejected, the candidate sought temporary injunctive relief in a state district court. The trial court denied this request, and the candidate did not appeal the denial or seek emergency relief from the court of appeals. Instead, he pursued a writ of mandamus from the Supreme Court of Texas, arguing that the party chair had a ministerial duty to accept his amended application and certify him as a candidate.The Supreme Court of Texas denied the petition for writ of mandamus. The court held that mandamus is inappropriate where there are genuinely disputed material facts, and noted that the trial court had ruled against the candidate on the core factual dispute regarding the sufficiency of his signatures. Further, the court concluded that the law does not require election officials to accept amendments to ballot applications after the statutory deadline, especially when initial submissions occur at the very end of the filing period. The court found no violation of a ministerial duty or clear abuse of discretion by the party chair and thus denied the extraordinary relief requested. View "In re Rogers" on Justia Law

Pedro Castaneda died in a traffic accident at an intersection on State Highway 249 that was under construction. At the time, the intersection’s traffic lights were installed but not yet operational, and there was a dispute about whether they were properly covered to indicate their status. Castaneda’s family sued the contractors involved in the project, SpawGlass Civil Construction, Inc. and Third Coast Services, LLC, alleging that negligence in the construction and installation of the traffic signals contributed to the fatal accident. The construction project was governed by an agreement between the Texas Department of Transportation (TxDOT) and Montgomery County, with the County responsible for the project’s design and construction, but with TxDOT retaining authority over the adjacent frontage roads and final approval of plans.The trial court denied the contractors’ motions for summary judgment that sought dismissal under Texas Civil Practice and Remedies Code Section 97.002, which grants immunity to contractors under certain conditions. The contractors appealed. The Fourteenth Court of Appeals affirmed, concluding that Section 97.002 applies only to contractors who are in direct contractual privity with TxDOT, and since neither contractor had a direct contract with TxDOT, they could not invoke the statute’s protection.The Supreme Court of Texas reversed the court of appeals. It held that Section 97.002 does not require direct contractual privity with TxDOT for a contractor to qualify for statutory immunity. The court determined that, based on the summary judgment record, SpawGlass and Third Coast performed work "for" TxDOT within the meaning of the statute, as their activities directly related to frontage roads that TxDOT would own and maintain. The court remanded the case to the court of appeals to determine whether the contractors met the remaining requirements of Section 97.002. View "THIRD COAST SERVICES, LLC v. CASTANEDA" on Justia Law