Justia Texas Supreme Court Opinion Summaries

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

The Supreme Court held that a negligence claim can arise from the condition or use of an improvement even when negligence elsewhere is alleged to have contributed to a plaintiffs' injuries so long as the other statutory requirements are satisfied.Plaintiffs brought claims for negligence, gross negligence, and trespass to chattels against Defendant, the owner of property upon which Plaintiffs were working to drill a water well. Plaintiffs brought this action alleging that there was negligence regarding a condition of the water well Plaintiffs were drilling, and this negligence caused damages. Defendant filed a motion for summary judgment, asserting that Chapter 95 of the Civil Practice and Remedies Code applied to Plaintiffs' claims. The trial court granted the motion. The court of appeals reversed. The Supreme Court reversed, holding (1) Chapter 95 applied; and (2) the trial court properly granted summary judgment because Defendant proved conclusively that it could not be held liable under Chapter 95 given its lack of control over the work. View "Energen Resources Corp. v. Wallace" on Justia Law

The Supreme Court reversed in part the decision of the court of appeals reversing the trial court's summary judgment in this case involving a school district's breach of warranty claims against a general contractor and an artificial-field-turf manufacturer, holding that the court of appeals erred.The Supreme Court reversed in part and reinstated the trial court's summary judgment in favor of the contractor, holding (1) a trial court’s on-the-record, oral ruling sustaining an objection to summary judgment evidence suffices to strike the evidence from the summary judgment record when the ruling is not reduced to a written order; and (2) the court of appeals erred in reversing the trial court's summary judgment in favor of the contractor and remanding the claims against the turf manufacturer for a new trial without addressing the merits of the issues on appeal that could result in rendition of judgment in favor of the manufacturer. View "FieldTurf USA, Inc. v. Pleasant Grove Independent School District" on Justia Law

The Supreme Court held that the Texas Workers' Compensation Act (TWCA) does not affect the enforceability of an additional-insured provision under the Texas Anti-Indemnity Act (TAIA).A general contractor's employee injured in an accident obtained a negligence judgment in Texas state court against the subcontractor that operated the crane (Berkel) and the company that leased the crane (Maxim). Berkel was an indemnity and Maxim was an indemnity for TAIA purposes because Berkel had provided Maxim with coverage as an additional insured. After the injured worker settled with Maxim, Maxim unsuccessfully sought reimbursement from Berkel's insurer (Zurich). The court of appeals reversed the judgment against Berkel, concluding that Berkel and the injured worker were "statutory co-employees" of the general contractor under the TWCA, and therefore, the TWCA provided the worker's exclusive remedy. In a separate suit in federal court, Maxim and Zurich disputed over whether the additional-insured coverage was enforceable. The Supreme Court answered a certified question by holding that the word "employee" in Tex. Ins. Code 151.103 bears its common meaning, which is not affected by whether the indemnity and injured employee are considered co-employees for purposes of the TWCA. View "Maxim Crane Works, LP v. Zurich American Insurance Co." on Justia Law

The Supreme Court held that a technical defect in personal service on a ward does not drive the probate court of subject-matter jurisdiction or personal jurisdiction over the ward where the ward is personally served and participates in the proceedings through counsel without objection.Petitioner, the daughter of Mauricette and James Fairley, asked the Supreme Court to void all orders entered in a guardianship proceeding in which Mauricette acted as James's guardian for the final three years of his life. Specifically, Petitioner alleged that personal service on her father by a private process server was insufficient to vest jurisdiction in the probate court because Chapter 1051 of the Estates Code requires a proposed ward to personally be served by a sheriff, constable, or other elected officeholder. The Supreme Court denied relief, holding that Petitioner failed to establish that any deficiency with respect to the method of personal service rose to the level of a violation of due process. View "In re Guardianship of Fairley" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the decision of the trial court denying Defendants' motion to dismiss Plaintiff's medical negligence claims, holding that Texas Medical Liability Act applied, and therefore, Plaintiff's failure to serve an expert report on Defendants was fatal to her claims.At issue was (1) whether Plaintiff's claims that Defendants negligently administered various treatments that caused scarring and discoloration to her skin constituted "health care liability claims" under the Act, and (2) whether the Act prohibited Plaintiff from filing an amended petition after the Act's deadline for serving expert reports. The Supreme Court held (1) Plaintiff's claims constituted health care liability claims subject to the Act's expert report requirements; (2) the Act did not prohibit Plaintiff from filing an amended petition; and (3) because Plaintiff failed timely to serve an expert report, Plaintiff's claims must be dismissed under the Act. View "Lake Jackson Medical Spa, Ltd. v. Gaytan" on Justia Law