Justia Texas Supreme Court Opinion Summaries

The Supreme Court held that remand is not the proper remedy for a successful factual-sufficiency challenge to Tex. Fam. Code 161.006(b)(1)(D) and (E) when termination is otherwise valid on another predicate ground.The trial court terminated Father's parental rights, basing its termination on three predicate grounds and finding that termination was in the child's best interest. The court of appeals affirmed termination under subsection 161.001(b)(1)(O) for failure to comply with the service. Because a predicate ground for termination under (M) is prior termination for endangerment under (D) or (E), however, the court of appeals examined the sufficiency of the evidence and held that the evidence for termination under subsections (D) and (E) was not factually sufficient. The court then remanded the case for a new trial on (D) and (E). The Supreme Court reversed in part, holding that the court of appeals erred in remanding the case for a new trial on the factually insufficient predicate grounds. View "In re M.P." on Justia Law

The Supreme Court affirmed the judgment of the court of appeals rendering judgment that delivery of the grantor's fractional share in the pipeline occurred in the gathering pipeline rather than the transportation pipeline, holding that the court of appeals did not err.A deed conveying the mineral estate in this case reserved a nonparticipating royalty interest in kind, meaning that the grantor retained ownership of a fractional share of all minerals in place. The deed required delivery of the grantor's fractional share "free of cost in the pipe line, if any, otherwise free of cost at the mouth of the well or mine[.]" The parties agreed that the royalty did not include production and postproduction costs incurred before delivery into the existing gas pipeline but disagreed about the pipeline's location under the terms of the deed. The trial court concluded that delivery occurred in the transportation pipeline. The court of appeals reversed, concluding that delivery occurs in the gathering pipeline. The Supreme Court affirmed, holding that the court of appeals correctly interpreted the deed in this case. View "Nettye Engler Energy, LP v. Bluestone Natural Resources II, LLC" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the judgment of the trial court terminating Father's parental rights to Child, holding that Father's evidence that he would be paroled in the near future was speculative.Child was born while Father was in prison. When Child was nineteen months old the trial court terminated Father's parental rights, finding that he would remain incarcerated and unable to care for Child for at least two years from the date the petition was filed. The court of appeals reversed, concluding that the Department of Family and Protective Services failed to negate Father's testimony that he would be paroled "in the near future." The Supreme Court reversed, holding that the court of appeals impermissibly substituted its own judgment for the trial court's judgment and erred by failing to defer to the trial court's assessment of the witnesses' credibility. View "In re C.L.E.E.G." on Justia Law

The Supreme Court held that, at least where specific jurisdiction is asserted, Tex. R. Civ. P. 120a discovery need not relate exclusively to jurisdictional issues without touching on merits issues.The parties in this suit concerning water leaks from plastic pipe made of cross linked polyethylene failed to agree on the scope of two corporate representative depositions, and so the trial court granted a motion to compel the depositions on a list of thirty topics proposed by Plaintiffs. The nonresident defendant sought mandamus relief, which the court of appeals granted, concluding that the trial court erred in compelling discovery on topics that touched both jurisdictional and merits issues. The Supreme Court directed the court of appeals to vacate its mandamus order, holding (1) the trial court did not abuse its discretion merely by compelling discovery on jurisdictional topics; (2) the standard for trial courts to apply is that the information sought must be essential to prove at least one part of the plaintiff's theory of personal jurisdiction; and (3) general principles that limit the scope of discovery apply equally to jurisdictional discovery. View "In re Christianson Air Conditioning & Plumbing, LLC" on Justia Law

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