Justia Texas Supreme Court Opinion Summaries

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

The Supreme Court reversed the judgment of the court of appeals affirming the decision of the trial court granting summary judgment in favor of Roy Elizondo and dismissing this action brought by Cadence Bank, N.A. for breach of a deposit agreement, breach of warranty under the Uniform Commercial Code (UCC), and common-law torts, holding that the lower courts erred.In response to a stranger's email for legal assistance, Elizondo, an attorney, deposited a cashier's check in his bank account then wired most of the funds to an overseas account. The check was dishonored, and the bank charged the transfer back to Elizondo, as allowed by the UCC and the parties' deposit agreement. When Elizondo refused to pay the overdrawn funds Cadence brought this action. The trial court granted summary judgment for Elizondo, and the court of appeals affirmed. The Supreme Court reversed, holding that the wire-transfer form failed to create the contractual duty urged by Elizondo. View "Cadence Bank, N.A. v. Elizondo" on Justia Law

The Supreme Court accepted a certified question from the United States Court of Appeals for the Fifth Circuit by answering that Texas law does not authorize certain state officials to directly or indirectly enforce the state's new abortion restriction requirements.Plaintiffs, who provided and funded abortions and support for women who obtain them in Texas, requested a declaration that Senate Bill 8, the "Texas Heartbeat Act," Tex. Health & Safety Code 171.201-.212, unconstitutionally restricted their rights and injunction prohibiting Defendants, state agency executives, from enforcing the Act's requirements. After a remand, the Fifth Circuit certified a question to the Supreme Court. The Supreme Court answered answered that Texas law does not grant the state agency executives named as defendants any authority to enforce the Act's requirements, either directly or indirectly. View "Whole Woman's Health v. Jackson" on Justia Law

In this premises-defect case, the Supreme Court denied the petition for writ of mandamus brought by Eagleridge Operating, LLC seeking relief from a trial court order striking its responsible-third-party designation under Chapter 33 of the Texas Civil Practice and Remedies Code, holding that Eagleridge failed to establish that it was entitled to the writ.In this action, Eagleridge argued that a former well site owner-operator bore continuing responsibility for injuries caused by a burst gas pipeline because the former owner acted as an independent contractor in constructing, installing, and maintaining the pipeline. The lower courts concluded that Occidental Chemical Corp. v. Jenkins, 478 S.W.3d 640 (Tex. 2016), was controlling and that the former owners' responsibility for premises defects did not survive the conveyance of its ownership interest. The Supreme Court agreed, holding that an agreement between tenants in common to allocate expenses, assign responsibilities, and compensate for disparate efforts in a joint endeavor does not create an exception to Occidental as to improvements each party would otherwise have been free to construct without the consent of the other. View "In re Eagleridge Operating, LLC" on Justia Law