Justia Texas Supreme Court Opinion Summaries

The Supreme Court held that the Texas Propane Gas Association (TPGA) demonstrated standing to bring its suit against the City of Houston for a declaratory judgment that the City's ordinances regulating the liquefied petroleum gas (LPG) industry to include imposing criminal fines for violations were preempted by state law.The City brought two jurisdictional challenges to TPGA's suit: (1) the City argued that civil courts lacked subject matter jurisdiction to adjudicate TPGA's preemption claim because the local regulations it challenged carried criminal penalties; and (2) the City argued that TPGA could only challenge the City's LPG regulations that have injured at least one of its members. The trial court refused to dismiss the suit for lack of jurisdiction. The court of appeals remanded the case to the trial court for TPGA to amend its pleadings, agreeing that TPGA could not challenge the City's regulations en masse. The Supreme Court reversed, holding (1) TPGA's claim was not a criminal law matter that must be raised in defense to prosecution; and (2) the City's argument, while framed as a challenge to TPGA's standing, was in fact a merits challenge, and TPGA demonstrated standing to bring the preemption claim it pleaded. View "Texas Propane Gas Ass'n v. City of Houston" on Justia Law

In this quiet title action, the Supreme Court reversed the summary judgment in favor of Defendant, holding that Defendant did not conclusively negate unsound-mind tolling pleaded as an exception to limitations.Plaintiff, a person who alleged a mental incapacity, sought to prevent Defendant, his aunt, from evicting him from property he had inherited, arguing that a deed to Defendant that he had signed years earlier was void due to his lack of capacity. Defendant moved for traditional summary judgment based on the statute of limitations. In response, Plaintiff invoked the unsound-mind tolling statute. The trial court granted summary judgment for Defendant. The court of appeals affirmed. The Supreme Court reversed, holding (1) because Defendant moved for traditional summary judgment on limitations and Plaintiff raised the unsound-mind tolling statute, Defendant had the burden to conclusively negate Plaintiff's assertion of mental capacity; (2) because Defendant offered no evidence regarding Plaintiff's soundness of mind, she failed to carry her burden; and (3) therefore, the court of appeals erred in affirming the trial court's order granting Defendant summary judgment. View "Draughon v. Johnson" on Justia Law

The Supreme Court conditionally granted a petition for writ of mandamus sought by the Diocese of Lubbock, as relator, asserting that ecclesiastical abstention prohibits the trial court from assuming jurisdiction over a suit brought by one of its ordained deacons against the Diocese and that, therefore, the trial court should have granted the Diocese's plea to the jurisdiction, holding that dismissal of the deacon's underlying lawsuit was required.This lawsuit arose out of an investigation by the Diocese into its clergy and the inclusion of the deacon's name on a list of the Diocese's clergy credibly accused of sexual abuse of a minor, as well as the Diocese's public statements regarding the list following its release to the Diocese's public website. The court of appeals concluded that the Diocese's investigation lost ecclesiastical protection when it related to the issue of sexual abuse, which is not strictly and purely ecclesiastical. The Supreme Court granted the Diocese's petition for writ of mandamus and directed the trial court to dismiss the deacon's underlying lawsuit, holding that exercising jurisdiction over the underlying case would encroach on the Diocese's decision to investigate its clergy consistent with its internal policies. View "In re Diocese of Lubbock" on Justia Law

The Supreme Court vacated the trial court's underlying interlocutory order denying a motion to dismiss under the Texas Citizens Participation Act (TCPA), Tex. Civ. Prac. & Rem. Code 27.003, and the judgment of the court of appeals denying the Diocese of Lubbock's mandamus petition, holding that the trial court lacked jurisdiction to proceed in the underlying litigation.The claims at issue arose out of the Diocese's inclusion of Jesus Guerroro's name on a list of clergy credibly accused of sexual abuse. Guerroro sued, claiming defamation and intentional infliction of emotional distress. The Diocese filed a plea to the jurisdiction and followed the plea with a motion to dismiss under the TCPA. The trial court denied both. The court of appeals denied the Diocese's mandamus petition and affirmed the trial court's TCPA order with respect to the defamation claim. The Supreme Court vacated the orders below, holding (1) the ecclesiastical abstention doctrine deprived the trial court of jurisdiction over Guerroro's suit; and (2) therefore, the trial court erred by not sustaining the Diocese's plea to the jurisdiction and dismissing the underlying case. View "Diocese of Lubbock v. Guerrero" on Justia Law

In this tax exemption case concerning privately owned real property in Galveston County the Supreme Court affirmed the judgment of the court of appeals affirming the district court's grant of summary judgment for the Galveston Central Appraisal District, holding that Odyssey 2020 Academy was not entitled to an exemption from the ad valorem tax.The property at issue was subleased by Odyssey, which used the property to operate a public charter school. Odyssey contractually agreed to pay the property owners' ad valorem taxes and requested that the Galveston Central Appraisal District exempt the property from taxation as "property owned by this state" under section 11.11(a) of the Tax Code. The District denied the exemption request. On review, the district court granted summary judgment for the District. The court of appeals affirmed. The Supreme Court affirmed, holding that, on these facts, the Constitution does not merit an exemption for Odyssey. View "Odyssey 2020 Academy, Inc. v. Galveston Central Appraisal District" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals concluding that Petitioners (collectively, BPX) were not entitled to summary judgment on the issue of whether Margaret Strickhausen impliedly ratified an unauthorized pooling agreement, holding that BPX did not establish implied ratification as a matter of law.BPX was a lessee of Strickhausen's mineral interest. The lease required BPX to obtain Strickhausen's express written consent before pooling her tract with others. Strickhausen never gave express written consent to BPX, which meant that BPX could not pool "under any circumstances." Strickhausen sued BPX for breach of contract, among other claims, after BPX filed a certificate of pooling authority for a well on her tract. BPX filed a motion for summary judgment, arguing that Strickhausen impliedly ratified the pooling because she accepted royalty payments calculated on a pooled basis. The trial court granted an interlocutory summary judgment for BPX on Strickhausen's wrongful pooling, commingling, and failure to account claims. The court of appeals reversed. The Supreme Court affirmed, holding that summary judgment for BPX on the issue of implied ratification was improper. View "BPX Operating Co v. Strickhausen" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Homeowners' request seeking declaratory judgment that the Historic Preservation Ordinance adopted by the Houston City Council was void and unenforceable because it violated the City Charter's limits on zoning and did not comply with certain provisions of Chapter 211 of the Local Government Code, holding that the City did not violate either its Charter or the provisions of Chapter 211.Specifically, the Supreme Court held (1) the ordinance did not implement zoning as that concept is ordinarily understood, and therefore, the City Charter's limits on zoning did not apply in this case; and (2) while Chapter 211 did apply to the ordinance, Plaintiffs failed to prove that the ordinance violated the requirements of Chapter 211 at issue in this case. View "Powell v. City of Houston" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the judgment of the trial court naming Aunt and Uncle managing conservators of parents' two children, naming Mother and Father possessory conservators, and stating that, in the absence of mutual agreement, Mother could have supervised visitation with the children at the discretion of the managing conservator, holding that there was no error.In affirming, the court of appeals determined that the evidence was sufficient to support the terms of the visitation order, that the terms of the order were permissible upon a finding that they were in the best interest of the children, and denying Mother's constitutional challenge to Tex. Fam. Code 262.201(o). The Supreme Court affirmed, holding (1) because the trial court could have reasonably concluded that a restriction on Mother's right of access was in the children's best interest, there was not abuse of discretion; and (2) Mother's constitutional challenges were rendered moot by the trial court's issuance of a final order. View "In re J.J.R.S." on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the decision of the trial court denying Defendant's motion for directed verdict as to nine of thirteen allegedly defamatory statements, holding that the trial court did not err in denying Defendant's motion for directed verdict as to the nine disputed statements.The court of appeals concluded that only four of thirteen statements submitted to the jury in a nonsegregated jury question met the requirements of the Defamation Mitigation Act (DMA) and reversed and remanded for a new trial with respect to only those four defamation claims. The Supreme Court reversed, holding (1) the DMA provides of the abatement of claims and loss of exemplary damages, rather than dismissal; and (2) because that remedy was available to Defendant when Plaintiff amended his complaint to add the nine disputed statements, the trial court did not abuse its discretion in denying Defendant's motion for directed verdict as to those claims. View "Hogan v. Zoanni" on Justia Law

The Supreme reversed the decision of the court of appeals reversing the judgment of the trial court dismissing a will contestant's lawsuit for lack of standing, holding that because the contestant did not rebut the evidence established by the will's proponent the the contestant accepted benefits under the will to which she was not otherwise legally entitled, the trial court properly dismissed the contest.Before his death, Dempsey Johnson executed a will devising his estate through specific bequests and leaving the residuary to his three daughters, including Tia MacNerland. After Johnson died, MacNerland sued the estate's executor seeking to set aside Johnson's will on the grounds that he was unduly influenced when he executed the will. The trial court dismissed the will contest for lack of standing under the acceptance-of-benefits doctrine. The court of appeals reversed, concluding that the executor failed to demonstrate that MacNerland accepted greater benefits than those to which she was entitled under the will or intestacy laws. The Supreme Court reversed, holding that because MacNerland accepted benefits under Johnson's will, the trial court properly dismissed her challenge to the will's validity. View "In re Estate of Johnson" on Justia Law