Justia Texas Supreme Court Opinion Summaries

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

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