Justia Texas Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals affirming the decision of the trial court denying Aerotek, Inc.'s motion to compel arbitration, holding that an alleged signatory's simple denial that he signed the record was insufficient to prevent attribution of an electronic signature to him.Plaintiffs, four individuals, were hired by Aerotek to work as contractors on a construction project. After all four were terminated, they sued Aerotek and others for racial discrimination and retaliation. Aerotek moved to compel arbitration based on an online-only hiring application that each employee had completed. Plaintiffs opposed the motion, arguing that they had completed the online hiring application but denying that they had ever seen or signed a mutual arbitration agreement (MAA) within the application. The trial court denied the motion to compel arbitration. The court of appeals affirmed, rejecting Aerotek's argument that it had conclusively established the validity of the MAAs. The Supreme Court reversed, holding (1) Aerotek conclusively established that Plaintiffs signed, and therefore consented to, the MAAs; and (2) therefore, the trial court erred in denying Aerotek's motion to compel arbitration. View "Aerotek, Inc. v. Boyd" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the court of appeals concluding that the Commissioner of Education had jurisdiction over a group of teachers' grievances and that some of the grievances were untimely and others were timely, holding that the grievances were timely filed.Teachers at Dallas Independent School District (DISD) objected to the district's method of evaluating teacher performance and filed grievances. DISD denied the grievances as untimely. The Teachers appealed to the Commissioner, who concluded that the untimely presentation of the grievances to the school board deprived him of jurisdiction. The district court affirmed. The court of appeals affirmed in part and reversed in part. The Supreme Court affirmed in part and reversed in part, holding (1) the Commissioner had jurisdiction to hear the appeal of the Teachers' grievance; (2) the Teachers' grievance was timely filed with DISD, and therefore, the portion of the court of appeals' judgment upholding the dismissal of portions of the grievance as untimely was erroneous; and (3) the portion of the court of appeals' opinion reversing the dismissal of part of the grievance is affirmed. View "Davis v. Morath" on Justia Law

The Supreme Court conditionally granted a writ of mandamus and ordered the trial court to vacate its order denying K&L Auto Crushers' motion for reconsideration, holding that the trial court abused its discretion by denying K&L Auto's requested discovery and that K&L Auto had no adequate remedy by way of appeal.Kevin Walker, who was injured in a motor-vehicle collision with a tractor-trailer rig driven by Thomas Gothard, sued Gothard and his employer, K&L Auto. K&L Auto served subpoenas on Walker's healthcare providers requesting production of information related to their billing practices and rates. Three of the providers filed motions to quash the subpoenas on several grounds. The trial court quashed the subpoenas without explanation. K&L Auto moved for reconsideration, stating that it was willing to enter into a protective order and narrow its requests. The trial court denied the motion. The Supreme Court granted a writ of mandamus, holding that the information sought through K&L Auto's narrowed requests was relevant and that the trial court abused its discretion by completely denying discovery of that information. View "In re K&L Auto Crushers, LLC" on Justia Law

The Supreme Court affirmed the judgment of the trial court terminating Father's parental rights to his daughter, Julie, holding that the evidence supported the trial court's finding that Father engaged in conduct that endangered Julie's physical or emotional well-being.Julie was an infant when Father reported to prison. Father emerged from prison when Julie was an adolescent and living with a foster family with her half-sisters. After a hearing, the trial court found by clear and convincing evidence that the State had met its burden of proof to terminate Father's parental rights to Julie on the ground that Father had engaged in conduct or knowingly placed Julie with persons who engaged in conduct that endangered the physical or emotional well-being of Julie. The court further found that termination of Father's parental rights was in Julie's best interest. The Supreme Court affirmed, holding that the evidence supported the trial court's findings and that the trial court did not abuse its discretion in terminating Father's parental rights. View "In re J.F.-G." on Justia Law

In this case involving the scope of the attorney-immunity defense, the Supreme Court held that attorney immunity applies in all adversarial contexts in which an attorney has a duty to zealously represent a client, including in a business-transactional context, but only when the claim against the attorney is based on the type of conduct attorney immunity protects.At issue was whether the attorney-immunity defense applies to a non-client's claims that are based on an attorney's conduct performed outside of the context of litigation. The court of appeals reversed the trial court's summary judgment in this case, concluding that attorney immunity does not extend beyond the litigation context and should not be extended to a business transaction. The Supreme Court reversed, holding (1) attorney immunity provides a defense to a non-client's claims based on an attorney's conduct that constitutes the provision of legal services involving the unique office of an attorney and the conduct that the attorney engages in to fulfill the attorney's duties in representing the client within an adversarial context in which the client and the non-client do not share the same interests; and (2) attorney immunity applies to claims based on conduct the attorney performed in a non-litigation context so long as the conduct qualifies as this "kind" of conduct. View "Hayes & Boone, LLP v. NFTD, LLC" on Justia Law

The Supreme Court affirmed the determination of the court of appeals that the Uniform Declaratory Judgments Act (UDJA), Tex. Civ. Prac. & Rem. Code 37.001-.011, can be used to establish an insurance carrier's liability for benefits under an underinsured motorist (UIM) policy, holding that a declaratory judgment action can be used for this purpose.On appeal, the Insurer argued that Insured's use of the UDJA to determine Insured's contract rights and to seek attorney's fees in the UIM case impermissibly dodged the Supreme Court's decision in Brainard v. Trinity Universal Insurance Co., 216 S.W.3d 809 (Tex. 2006). The court of appeals affirmed. The Supreme Court affirmed as well, holding (1) a declaratory judgment in the instant case was the proper remedy for resolving this contractual dispute; and (2) attorney's fees may be recovered under the UDJA under the circumstances. View "Allstate Insurance Co. v. Irwin" on Justia Law

The Supreme Court reversed the judgment of the court of appeals holding that an attorney's pre-suit efforts to publicize allegedly defamatory statements are shielded from liability by either attorney immunity or the judicial-proceedings privilege, holding that the court of appeals erred as to this issue.Landry's, Inc. sued Defendants for defamation, business disparagement, tortious interference, abuse of process, trespass, and civil conspiracy. The trial court granted Defendants' motions to dismiss pursuant to the Texas Citizens Participation Act (TCPA). The court of appeals affirmed, holding that the judicial-proceedings privilege immunized Defendants from liability for the allegedly defamatory statements. The Supreme Court reversed in part, holding (1) the dissemination of the allegedly defamatory statements was not protected by the judicial-proceedings privilege, nor did the privilege cover other publicity statements; (2) attorney immunity did not bar Landry's defamation claims; and (3) the court of appeals correctly affirmed the dismissal of the business disparagement and tortious interference claims. View "Landry's, Inc. v. Animal Legal Defense Fund" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the denial of Petitioner's petition to expunge his driving while intoxicated (DWI) arrest records pursuant to Tex. Crim. Proc. Code 55.01(a)(2)(A), holding that the court of appeals erred in holding that Petitioner's DWI arrest records were not eligible for expunction under article 55.01(a)(2).At issue was whether an arrest involving multiple offenses is divisible for purposes of expunging arrest records under article 55.01. The court of appeals applied the "arrest-based" construction of the statute, under which expunction is available only if all of the offenses comprising an arrest are eligible for expunction. The Supreme Court reversed, holding (1) under article 55.01(a)(2)(A), misdemeanor offenses are eligible for expunction on an individual basis; and (2) Petitioner was entitled to partial expunction of his arrest records. View "Ex Parte R.P.G.P." on Justia Law

The Supreme Court reversed the judgment of the court of appeals holding that Tex. R. App. P. 26.1 did not apply to an inventor's motion for a new trial when the trial court struck the intervenor's petition before it rendered the final judgment, holding that, contrary to the conclusion of the court of appeals, Rule 26.1 does apply.A condominium owner and his homeowners' association and property manager settled the owner's claims asserting that Defendants wrongfully foreclosed their lien against the owner's condominium. In light of the settlement, the trial court struck the intervention petition of the owner's accounting firm (firm) and rendered final judgment. Thereafter, the firm filed a motion for new trial and a notice of appeal. The court of appeals dismissed the appeal for want of jurisdiction, concluding that the firm did not qualify as a "party" whose new trial motion could extend the appellate deadline. The Supreme Court reversed, holding (1) the firm was a party to the judgment, and therefore, its timely filing of the new trial motion extended the deadline for filing a notice of appeal; and (2) the firm timely filed its notice of appeal. View "Eichner v. Dominguez" on Justia Law

The Supreme Court reversed the judgment of the court of appeals ruling that a validly executed correction instrument under Tex. Prop. Code 5.029 must be signed by the property's current owners, holding that the court of appeals incorrect interpreted the "if applicable" clause in the statute.To be effective, the instrument correcting a material error in a recorded original instrument of conveyance by agreement must be executed by each party to the original instrument or, "if applicable, a party's heirs, successors, or assigns." See section 5.029(b)(1). At issue as when are a party's heirs, successors or assigns are applicable such that their agreement is necessary to make such a correction. The court of appeals concluded that the original parties could not correct their mistake in the original instrument of conveyance solely by their agreement after an assignment and, rather, a validly executed correction instrument under section 5.029 must be signed by the property's current owners. The Supreme Court reversed, holding (1) the original parties to a recorded original instrument of conveyance may validly execute a correction instrument under section 5.029, even after a third party has acquired an interest in the original transaction; and (2) the statute does not require that an original party's "heirs, successors, or assigns" sign a correction agreement when the original parties all execute the correction. View "Broadway National Bank v. Yates Energy Corp." on Justia Law