Justia Texas Supreme Court Opinion Summaries

In this dispute between a homeowners' association and a townhome owner the Supreme Court reversed the opinion of the court of appeals affirming the judgment of the trial court enjoining the owner from renting its townhomes for terms of fewer than seven days, holding that the association had no authority to impose a short-term rental restriction.After the association demanded that the owner stop leasing its townhomes for short-term rentals the owner sued to enforce a covenant in the neighborhood's deed restrictions granting it the right to lease without restriction. The trial court ruled that the short-term rentals breached a provision in the neighborhood's deed restrictions. The court of appeals affirmed, concluding that the association possessed independent authority under Tex. Prop. Code 204.010(a)(6) to restrict short-term rentals. The Supreme Court reversed, holding that neither the deed covenants nor the Property Code authorized the association to impose a short-term rental restriction. View "JBrice Holdings, LLC v. Wilcrest Walk Townhomes Ass'n" on Justia Law

In this wrongful death and survival action brought against an automobile insurer, the Supreme Court reversed the judgment of the court of appeals reversing the trial court's judgment in favor of the insurer as to Plaintiff's negligence and gross negligence claims, holding that the court of appeals erred.An insured motorist was involved in a single car accident. The motorist's husband later arrived and began taking photos, but while he was engaged in that activity on the side of the road, he was struck by another vehicle and killed. Plaintiff, the motorist, brought this action alleging that the insurer had instructed her to take the photos and that her husband was complying with that instruction when the other driver hit him. Thus, Plaintiff argued, the insurer proximately caused her husband's death. The trial court granted summary judgment for the insurer on the negligence and gross negligence claims. The court of appeals reversed. The Supreme Court reversed, holding that Defendant did not have a duty to exercise reasonable care in providing post-accident guidance so as not to increase the risk of harm to its insured. View "Elephant Insurance Co., LLC v. Kenyon" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the trial court's judgment for Plaintiff, a cardiovascular surgeon who sued Defendant, a hospital and Plaintiff's former employer, for engaging in a retaliatory "whisper campaign" against him, holding that the lower courts erred.After leaving the employment of Defendant for a new rival, Plaintiff brought this complaint alleging that Defendant used faulty data on his patients' mortality rates to suppress competition and injure his reputation and practice. The jury rejected Plaintiff's anticompetition claims but concluded that the hospital had defamed him and disparaged his professional association. The trial court granted summary judgment for Plaintiff, and the court of appeals affirmed. At issue on appeal was how a reasonable juror would interpret the charge that was given for the defamation and business disparagement claims. The Supreme Court held (1) the plain text of the charge must be given its commonsense meaning in the context of the case; and (2) the trial court erred in awarding Plaintiff damages for defamation and business disparagement. View "Memorial Hermann Health System v. Gomez" on Justia Law

The Supreme Court reversed the judgment of the court of appeals as to attorney's fees in this case concerning whether Defendant, a condominium association, was entitled to attorney's fees after obtaining a take-nothing judgment on claims by Plaintiff, a unit owner, the Supreme Court held that the fee award was authorized by Tex. Prop. Code 82.161(b).Plaintiff sued Defendant for, among other things, fraud, civil conspiracy, breach of contract, and negligence. Defendant filed a counterclaim for declaratory judgment and requested attorney's fees. The trial court granted Defendant's motion on twelve declaratory issues. After a trial, the court granted judgment for Defendant and awarded attorney's fees. The court of appeals affirmed the judgment for Defendant but reversed the award of attorney's fees. The Supreme Court reversed in part, holding that Defendant was a prevailing party under Tex. Prop. Code 82.161(b) and was thus entitled to reasonable attorney's fees. View "Sunchase IV Homeowners Ass'n v. Atkinson" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the judgment of the trial court, rendered pursuant to a jury verdict, that Stephen Stelly owned real property free of any encumbrance, holding that Stelly adequately pleaded a trespass-to-try-title claim.Stelly brought this action against John DeLoach claiming that DeLoach had breached the parties' contract by not delivering a real property deed after Stelly had paid off the debt on the land's original purchase price.The jury entered a verdict in favor of Stelly. The court of appeals reversed, concluding that Stelly pleaded only a breach-of-contract claim, not a trespass-to-try-title claim and that the statute of limitations had run on Stelly's breach of contract claim. The Supreme Court reversed and remanded the case for further proceedings, holding that Stelly adequately pleaded a trespass-to-try-title claim. View "Stelly v. DeLoach" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the judgment of the trial court denying San Antonio City's jurisdictional challenge to the "Save Chick-fil-A law" based on governmental-immunity grounds and dismissing the case, holding that the pleading did not affirmatively negate the existence of jurisdiction.The statute at issue prohibits a governmental entity from taking any adverse action against any person based on the person's membership in or support of a religious organization. Petitioners sued the City of San Antonio after it voted to prohibit the opening of a Chick-fil-A in the San Antonio airport based, at least in part, on Chick-fil-A's contributions to particular religious organizations that members of the city council found objectionable and seeking declaratory and injunctive relief. The City sought dismissal based on governmental immunity and lack of standing. The trial court denied the City's jurisdictional challenges. The court of appeals reversed and dismissed the case for lack of jurisdiction. The Supreme Court reversed, holding (1) Petitioners' pleading did not allege sufficient fact to invoke a waiver of governmental immunity; but (2) because the pleading did not affirmatively negate jurisdiction, Petitioners were entitled to an opportunity to replead. View "Von Dohlen v. City of San Antonio" on Justia Law

The Supreme Court reversed the decision of the court of appeals apportioning to Texas all of Sirius XM Radio's receipts from Texas subscribers, holding that Sirius's monthly subscription fees from Texas users were not receipts from a "service performed in this state."To calculate the franchise tax it owes to the state of Texas, Sirius must first calculate its receipts from each service performed in the state. See Tex. Tax Code 171.103(a). Before the Supreme Court, Sirius argued that the service it performs for its Texas subscribers is the production of radio shows and the transmission of a radio signal, almost all of which takes place outside of the state. The Supreme Court agreed and reversed the court of appeals' holding that the service performed by Sirius for Texas subscribers was unscrambling the radio signal. The Supreme Court reversed, holding (1) Sirius had little personnel or equipment in Texas that performs the radio production and transmission services for which its customers pay monthly subscription fees; and (2) therefore, the court of appeals erred in apportioning to Texas all of Sirius's receipts from Texas subscribers. View "Sirius XM Radio, Inc. v. Hegar" on Justia Law

The Supreme Court conditionally granted relief in this mandamus action and directed the secretary of the city of West Lake Hills to accept Linda Anthony's application and place her on the ballot as a candidate for Mayor of the City of West Lake Hills, holding that Anthony was entitled to relief.Anthony, the current Mayor of West Lake Hills, submitted a 2022 ballot application that left blank the box for the applicant's occupation. The city secretary rejected the application because it did not provide all of the information required by Tex. Elec. Code 141.031, thus excluding Anthony from a place on the ballot as candidate for mayor. The Supreme Court conditionally granted relief, holding (1) Anthony's application was not defective for failing to list an occupation when she currently had no paid employment; and (2) therefore, the city secretary had no discretion to reject Anthony's application. View "In re Anthony" on Justia Law

The Supreme Court reversed the judgment of the court of appeals ruling that the parties' contract in this case and its arbitration provision were unenforceable on the grounds that the parties never had a meeting of the minds on the contract, holding that the parties formed the agreement reflected in the contract they signed.Plaintiffs, members of the family of a woman killed in a high-speed crash while riding in a car driven by an intoxicated adult entertainer employed by Defendant, sued for wrongful death and survival damages, alleging that Defendant continued serving the driver alcohol after knowing she was clearly intoxicated. Defendant moved to compel arbitration pursuant to a contract containing an arbitration provision that the decedent and Defendant had signed almost two years earlier. The trial court denied the motion. The court of appeals affirmed, concluding that the terms in the contract were not perfectly clear, and therefore, there was no meeting of the minds. The Supreme Court reversed, holding that the contract terms were sufficient to constitute an enforceable contract. View "Baby Dolls Topless Saloons, Inc. v. Sotero" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the trial court's grant of summary judgment in this case brought under Chapter 95 of the Civil Practice and Remedies Code, holding that because the landowner conclusively established that Plaintiff was adequately warned of the dangerous condition, the trial court properly granted summary judgment.Plaintiff was working as a power lineman for OTI Energy Services when he was injured while working to de-energize part of an energized power line and transformer. Plaintiff sued SandRidge Energy, which hired OTI, for negligence, alleging that SandRidge could not establish a defense under Chapter 95 because it exercised control over the manner in which he performed the work, knew of the dangerous condition, and failed adequately to warn him of that condition. The trial court granted summary judgment for SandRidge. The court of appeals reversed, holding that Plaintiff had raised a fact issue as to whether SandRidge failed to provide an adequate warning. The Supreme Court reversed, holding (1) the evidence conclusively established that Plaintiff was fully aware of the dangerous condition that caused his injury; and (2) therefore, the trial court properly granted summary judgment. View "SandRidge Energy, Inc. v. Barfield" on Justia Law