Justia Texas Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the trial court dismissing this suit brought under the Death on the High Seas Act and maritime law, see 46 U.S.C. 30301 et seq., for lack of subject matter jurisdiction, holding that the issue presented were capable of judicial management without interfering with the military's judgment.A private contractor maintained a fleet of older Navy helicopters. In 2014, one of the helicopters crashed during a training exercise, killing three service members and injuring two others. Plaintiffs, the families of the deceased service members and one of the survivors, sued the contractor. The trial court dismissed the suit on the ground that questions of military judgment rendered the case nonjusticiable. The court of appeals affirmed. The Supreme Court reversed and remanded the case, holding that the political question doctrine did not deprive the state courts of jurisdiction over this case. View "Preston v. M1 Support Services, L.P." on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the court of appeals reducing the consequential damages awarded by the jury in this breach of contract action, holding that neither the jury's award of $56.3 million nor the court of appeals' reduced allowance of $12.4 million could stand.After a trial, a jury found Defendant breached a contract with Plaintiff by failing to pay $2.4 million as promised. The jury awarded $2.4 million as direct damages and then added more than twenty times that amount in consequential damages. The court of appeals reversed in part, concluding that consequential damages were authorized in the amount of $12.4 million. The Supreme Court reversed in part and affirmed in part and rendered judgment that Plaintiff take nothing on its claim for consequential damages and reducing Plaintiff's recovery of direct damages, holding (1) legally insufficient supported the award of consequential damages; (2) the direct damages award is reversed in part; and (3) the court of appeals properly rejected Defendant's indemnification claim and its rendition of judgment against co-plaintiff Jeffry Ogden. View "Signature Industrial Services, LLC v. International Paper Co." on Justia Law

The Supreme Court held that no contract to settle a debt was formed in this case, that the implied-revocation doctrine is not constrained to real-property transactions, and that the settlement offer was impliedly revoked when the offeror assigned the underlying judgment.At issue in this contract dispute was whether a purported offer to settle a debt for a reduced sum was accepted before it was revoked. The issue's resolution turned on the parameters of the doctrine of implied revocation adopted by the Supreme Court in Antwine v. Reed, 199 S.W.2d 482 (Tex. 1947). The trial court granted summary judgment against the offeree. The court of appeals reversed. The Supreme Court reversed, holding (1) the implied-revocation doctrine is not limited to offers involving the sale of land; and (2) the settlement offer in this case was impliedly revoked when the offeror assigned the underlying judgment to a third party for collection and the assignee gave the offeree a copy of the assignment agreement before the offeree accepted the settlement offer. View "Angel v. Tauch" on Justia Law

The Supreme Court reversed the decision of the trial court granting summary judgment for Petitioners and dismissing Respondents' allegations that Petitioners conspired to restrain trade in the movie-theater market in violation of section 15.05(a) of the Texas Free Enterprise and Antitrust Act, holding that Respondents set forth sufficient evidence to survive a motion for summary judgment.In Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574, 588 (1986), the United States Supreme Court held that, in order to survive a motion for summary judgment, a plaintiff seeking damages for a violation of section 1 of the Sherman Antitrust Act, must present evidence that "tends to exclude the possibility" that the alleged conspirators acted independently. The parties agreed that this requirement governed in cases brought under the Texas Antitrust Act but disagreed on its application in this case. The court of appeals held that Respondents satisfied this requirement. The Supreme Court reversed after construing the Texas Antitrust Act in harmony with federal law, holding that Respondents' evidence was not enough to survive summary judgment under the Texas Act. View "AMC Entertainment Holdings, Inc. v. IPic-Gold Class Entertainment, LLC" on Justia Law

The Supreme Court denied Relators' petition for writs of mandamus arguing that the Harris County Commissioners Court had stripped more than one million Texans of their right to vote for a commissioner in the 2022 election, holding that this petition could not go forward under settled precedents sharply limiting judicial authority to intervene in ongoing elections.Relators asked the Court to enjoin the use of a map enacted by the commissioners court, claiming to be in possession of an alternative map that lawfully redrew precincts without excluding any voter from consecutive county-commissioner elections. The Supreme Court denied the writ, holding that this Court lacked the ability to address the merits of this petition due to certain timing and nature-of-relief problems discussed in this opinion. View "In re Khanoyan" on Justia Law

The Supreme Court rendered judgment dismissing Petitioner's claims regarding his civil commitment as a sexually violent predator (SVP), holding that all of Petitioner's claims failed as a matter of law.Following a trial, a jury found that Petitioner was an SVP and issued a civil commitment order placing Petitioner in outpatient treatment and setting forth certain conditions. Petitioner later brought this lawsuit against the Texas Civil Commitment Office (TCCO) and the director of the office (collectively, the State), alleging that the TCCO's cost-recovery rules were invalid. The State filed a plea to the jurisdiction asserting immunity from suit. The district court dismissed all claims against the State except Petitioner's due process and takings claims. The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding that all of Petitioner's claims against the State failed as a matter of law and that the State's plea to the jurisdiction should have been granted in full. View "Matzen v. McLane" on Justia Law

The Supreme Court held that a gold-coin dealer sustained its loss consequent upon handing over its coins against fraudulent checks and that the shipper's alleged negligence in rerouting the shipment was not an independent cause of the loss.The dealer in this case purchased insurance to cover its shipments against physical loss, and the policy excluded losses "consequent upon" the dealer's handing over its coins to another against fraudulent checks. A thief had paid the dealer for two shipments of coins using fraudulent checks, and after the checks cleared, the dealer shipped the coins to the thief. Using the tracking information accompanying the shipment, the thief convinced the shipper to reroute the coins from their initial destination to a pickup facility. The dealer made claims under its policy with its insurer, seeking to recover the value of the coins. The insurer denied almost all requested coverage. The Supreme Court answered certified questions of law and held (1) a loss sustained "consequent upon" an event connotes but-for causation under the policy's exclusion of coverage for property handed over to a third party against a fraudulent check; and (2) the third-party shipper's alleged negligence was a concurrent cause of the loss, dependent upon handing over the property against the fraudulent checks. View "Dillon Gage Inc. of Dallas v. Certain Underwriters at Lloyds" on Justia Law

The Supreme Court held that Corpus Christi pharmacist John McNeill, who participated in a Medicaid drug program run by the Texas Health and Human Services Commission, was entitled to an administrative contested case hearing as to his challenge to the results of a program audit by the Commission.After the Commission audited McNeill, the auditor determined that McNeill had been overpaid by $69,911. McNeill requested a hearing, after which the Commission issued a final notice that reduced the overpayment amount to $64,549. McNeill thrice requested a contested case hearing before the State Office of Administrative Hearings. The Commission denied each request. McNeill sued the Commission, its commissioner, and its inspector general, seeking a declaration that he was entitled to a contested case hearing. The trial court granted the Commission's plea to the jurisdiction based on sovereign immunity and dismissed the complaint. The court of appeals reversed. The Supreme Court reversed, holding (1) McNeill's appeal was timely; and (2) the Commission's inspector general acted ultra vires in failing to perform her ministerial duty to provide McNeill a contested-case hearing under Tex. Gov't Code 531.1201, and the inspector general was not entitled to sovereign immunity. View "Phillips v. McNeill" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the trial court's judgment entered upon a jury verdict awarding future damages of $50,000 for breach of a terminable-at-will rental contract, holding that no evidence supported the amount awarded by the jury.The jury in this case found that Pura-Flo breached its indefinite agreement to make monthly rental payments to Donald Clanton and failed to find that Pura-Flo had terminated the contract. The jury awarded $19,500 in past losses and future damages of $50,000. The court of appeals affirmed. The Supreme Court reversed, holding that both the fact and amount of future damages lacked reasonable certainty. View "Pura-Flo Corp. v. Clanton" on Justia Law

The Supreme Court conditionally granted mandamus relief and ordered the trial court to vacate its order denying ExxonMobil's discovery requests, holding that the trial court abused its discretion in that ExxonMobil lacked an adequate remedy on appeal.Nearly sixty plaintiffs sued ExxonMobil seeking millions of dollars in reimbursement for past medical expenses arising from a fire and explosion at ExxonMobil's Baytown Olefins Plant. During discover, ExxonMobil sought discovery of the services Plaintiffs received from certain medical providers. The trial court denied ExxonMobil's ensuing motion to enforce its requested discovery and granted Plaintiffs' motions for protection. ExxonMobil subsequently sought mandamus relief. The Supreme Court granted the requested relief, holding that because the trial court abused its discretion by denying ExxonMobil's discovery requests and ExxonMobil had no appellate remedy, ExxonMobil was entitled to mandamus relief. View "In re Exxon Mobil Corp." on Justia Law