Justia Texas Supreme Court Opinion Summaries

The Supreme Court conditionally granted Relator American Airlines, Inc.'s petition for a writ of mandamus seeking relief from an order compelling the oral deposition of a high-level corporation official, holding that Relator was entitled to relief.The real party in interest in this case, Dr. Donald Arnette, sued American, alleging that one of its gate agents had improperly accessed his personal information and used it to harass him. Arnette served American with a series of deposition notices for Elise Eberwein, one of the six officers on American's executive leadership team. After a hearing, the trial court issued an order requiring Arnette to serve a new deposition notice. When eight months had passed without service of the required deposition notice American filed a petition for writ of mandamus seeking relief from the trial court's order. The Supreme Court conditionally granted relief and directed the trial court to vacate the order compelling Eberwein's deposition, holding that the trial court abused its discretion in compelling Eberwein's testimony. View "In re American Airlines, Inc." on Justia Law

The Supreme Court conditionally granted Relator's mandamus petition seeking relief from an order of the trial court compelling Relator to produce a certain witness for oral deposition, holding that the trial court abused its discretion.Jay Adashera, an employee of a wholesale granite purveyor, died when two 400-pound granite slabs fell off a contractor's truck at his workplace. His survivors sued the granite company and the truck owners, Lazaro Cabrera, for negligence and wrongful death. The survivors obtained a default judgment against Cabrera and then added claims against Texan Millwork, Inc., the company who had hired Cabrera to fabricate the slabs into countertops. At issue was whether Cabrera was an independent contractor and not an employee of Texan Millwork at the time of the accident. To secure Cabrera's testimony, the survivors filed a motion to compel Texan Millwork to produce Cabrera, "its agent and/or employee" for deposition. The trial court granted the motion to compel, and the court of appeals granted Texan Millwork's petition for mandamus relief. The Supreme Court conditionally granted the petition, holding that because there was no evidence of retention, employment, or control at the time discovery was sought, the trial court erred in compelling Texan Millwork to produce Cabrera for an oral deposition. View "In re Texan Millwork" 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 the Pemberton Park Community Association (Association) on its complaint against Li for violations of several restrictive covenants found in the "Declaration of Covenants, Restrictions and Easements for Pemberton Park" (the Covenants) holding that the court of appeals erred.On appeal, Appellant argued that the court of appeals erred in concluding that Appellant failed to preserve for appeal her argument that the Association's enforcement of the Covenants was "arbitrary, capricious, or discriminatory," in violation of Tex. Prop. Code 202.004(a). The Supreme Court agreed and reversed, holding that Appellant preserved her argument for appeal. View "Li v. Pemberton Park Community Ass'n" on Justia Law

The Supreme Court reversed the decision of the court of appeals dismissing the appeal in this bill-of-review proceeding for want of jurisdiction, holding that the court of appeals erred in ruling that the trial court's order dismissing the bill-of-review petition was interlocutory.The court of appeals held that the trial court order dismissing the bill-of-review petition was not final because the trial court failed to include decree-like language adjudicating and disposing of the petition. The Supreme Court reversed, holding that the order was final where it (1) disposed of all claims and parties; (2) stated that it was a "final order"; and (3) declared that the legal effect of granting the motions to dismiss was the dismissal of the bill of review filed in the instant case. View "In re Guardianship of Jones" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the trial court's grant of summary judgment for Defendants in this trespass-to-try-title suit between the lessees of adjacent mineral estates, holding that the court of appeals erred.In its complaint, Plaintiff claimed that Defendants drilled wells either on Plaintiff's leasehold or closer to the lease line than allowed by Railroad Commission rules. Defendants argued in response that Plaintiff ratified an agreed boundary line, foreclosing Plaintiff's trespass claims. The trial court granted summary judgment for Defendants. The court of appeals reversed, concluding that a boundary stipulation between the fee owners of the two mineral estates, which Plaintiff accepted, was void and could not be ratified. The Supreme Court reversed, holding that the boundary stipulation was valid and that Defendants conclusively established their ratification defense. View "Concho Resources, Inc. v. Ellison" on Justia Law

The Supreme Court conditionally granted mandamus relief and directed the Austin City Council to revise the ballot language for a proposed ordinance that would establish minimum standards for the Austin Police Department "to enhance public safety and police oversight, transparency, and accountability," holding that Relator was entitled to relief, in part.The City Council chose to place the proposed ordinance before the voters for approval at the next general election. Rather than use the caption set for in the petition as the ballot language, the City Council approved its own description of the ordinance to be used and the ballot using language that differed materially from the caption in the petition. Relator brought this proceeding challenging the chosen ballot language. The Supreme Court conditionally granted mandamus relief, holding (1) the City correctly determined that the caption's omission of the ordinance's financial impact violated state law, requiring modification; but (2) the Austin City Charter forbade the remainder of the City's revisions to the petitioned caption. View "In re Petricek" on Justia Law

The Supreme Court conditionally granted Petitioner's petition for a writ of mandamus and directed the district court to rescind a temporary restraining order (TRO) issued by the district court prohibiting the Governor and the Speaker of the House (Defendants) from compelling the attendance of members of the Texas House of Representatives (Plaintiffs), holding that the Texas Constitution gives the House of Representatives the authority to physically compel the attendance of absent members.Plaintiffs fled the state on July 12, 2021 in order to deny the House a quorum, thus preventing the legislature, in special session, from enacting voting legislation they opposed. Plaintiffs fled the state to escape the jurisdiction of the House, whose rules provide that absent members may be arrested and their attendance secured and retained. Plaintiffs then brought this action seeking an injunction prohibiting their arrest. The district court granted a TRO prohibiting Defendants from compelling Plaintiffs' attendance by arrest or restraint. The Supreme Court directed the district court to rescind the TRO, holding that the district court abused its discretion by granting the TRO. View "In re Abbott" on Justia Law

In this matter concerning the general appropriations bill for the next biennium beginning September 1, 2021 the Supreme Court denied Relators' request for a writ of mandamus asserting that the Governor's veto of the Legislature's appropriation for its own operations threatened the Legislature's ability to operate and therefore violated the constitutional separation of powers, holding that this Court declines to settle a dispute between coequal branches of the government.The day before the eighty-seventh Legislature adjourned, Democratic members of the House of Representatives prevented passage of pending legislation that they had opposed by leaving the chamber. When the general appropriations bill was presented to the Governor several days later, the Governor vetoed the Legislature's appropriation for its own operations because "[f]unding should not be provided for those who quit their jobs early." In this mandamus proceeding, Relators - the House Democratic Caucus and the majority of Democratic House members - argued that the veto was an attempt to abolish the Legislature in violation of separation of powers principles. The Supreme Court denied relief, holding that this dispute was one between the members of one branch rather than one between the branches, and where the Governor has made funding for continued legislative operations through the end of September, relief in mandamus was not appropriate. View "In re Turner" on Justia Law

The Supreme Court denied CenterPoint Energy Houston Electric, LLC's petition for writ of mandamus in this negligence action, holding that the Texas Public Utility Commission (PUC) did not have exclusive jurisdiction to adjudicate issues of duty and breach that underlay Plaintiffs' claims.A good Samaritan was electrocuted in an attempt to help the victims of a wreck that downed a CenterPoint power line. The man's family and estate brought wrongful-death and survival claims against CenterPoint, alleging that CenterPoint had a duty to design, construct, operate, and maintain its electricity distribution system to de-energize portions of the distribution lines promptly when they experience faults. CenterPoint filed a plea to the jurisdiction, contending that the PUC's exclusive jurisdiction over an electric utility's rates, services, and operations extends to adjudicating whether its line-protection measures were lawful and complied with industry standards. The probate court denied CenterPoint's plea to the jurisdiction, after which CenterPoint filed a petition for writ of mandamus. The Supreme Court denied relief, holding that the PUC did not have exclusive jurisdiction over any issues underlying this common-law negligence dispute. View "In re Centerpoint Energy Houston Electric, LLC" on Justia Law

The Supreme Court answered in the negative a question posed by the United States Court of Appeals for the Fifth Circuit regarding whether Amazon.com is a "seller" under Texas law when it does not hold title to third-party products sold on its website but controls the process of transaction and delivery, holding that Amazon is not a "seller" of third-party products under Texas law.At issue was whether third-party e-commerce platforms such as Amazon, eBay, Etsy, and Alibaba are strictly liable for defective products manufactured and owned by third parties. The Supreme Court answered the question in the negative, holding (1) under the Legislature's definition of "seller" in Chapter 82 of the Civil Practice and Remedies Code, when the ultimate consumer obtains a defective product through an ordinary sale, the potentially liable sellers are limited to those who relinquished title to the product at some point in the distribution chain; and (2) because the product in this case was sold on Amazon's website by a third party and Amazon did not hold or relinquish title, Amazon was not a seller even though it controlled the process of the transaction and the delivery of the product. View "Amazon.com v. McMillan" on Justia Law