Justia Texas Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals holding that a fact issue existed as to whether a general contractor on a construction project owed a duty of care to its independent contractor's employee who was injured on the job, holding that no genuine issue of material fact existed regarding the existence of a duty.The trial court entered judgment in favor of the general contractor, concluding that there was no evidence to support the negligence elements of duty, breach, and causation. The court of appeals reversed as to the negligence claim, concluding that a fact issue existed regarding whether the contractor exercised actual control and thus owed the employee a duty, whether the contractor breached that duty, and whether the contractor's breach proximately caused the employee's injuries. The Supreme Court reversed, holding that the contractor owed the employee no duty as a matter of law. View "JLB Builders, LLC v. Hernandez" on Justia Law

The Supreme Court declined to issue mandamus relief to compel Commissioner George P. Bush, head of the General Land Office, to refer the City of Galveston's claim that that the Land Office owed reimbursement to the City, holding that the City was not entitled to mandamus relief.The dispute in this case arose from a block grant contract that required the City to administer federal disaster relief funds. The City hired a private contractor to do some of the work, and the private contractor later sued the City for alleged amounts owed under the parties' contract. After the City settled with the private contractor it filed a claim for reimbursement from the Land Office for the settlement amount paid by the City. Bush refused to refer the City's claim to the State Office of Administrative Hearings for an administrative law judge to hear it. The City brought this action asking that the Supreme Court exercise its original mandamus jurisdiction over state officials to compel Bush to refer the claim. The Supreme Court denied the petition for a writ of mandamus, holding that where, as part of the settlement, the City agreed not to sue Bush in any "related proceeding," mandamus relief was precluded. View "In re City of Galveston, Texas" on Justia Law

In this insurance dispute, the Supreme Court denied a writ of mandamus compelling the trial court to render judgment in favor of Insurer on the jury's verdict, holding that the trial court did not abuse its discretion in declining to render judgment on the verdict.Insured sought underinsured motorist (UIM) benefits from Insurer. Insurer in this case declined to participate in a jury trial to establish the at-fault motorist's liability and demanded a separate trial on its liability under the UIM policy. Before trial on the UIM claim, the court commenced a jury trial on Insured's negligence claim against the at-fault motorist. The parties settled and the claim was dismissed without rendition of judgment on the jury's verdict. Insurer then argued that a separate trial on the UIM claim was no longer necessary because of the jury's findings and the settlement payment. The trial court denied Insurer's motion for judgment based on the jury verdict from the negligence trial. Insurer sought mandamus relief. The Supreme Court denied relief, holding (1) collateral estoppel did not bind Insured to a verdict that was not reduced to judgment; and (2) Insurer's post-dismissal consent to be bound by the negligence suit's outcome did not make the negligence verdict enforceable against Insured in the contract suit. View "In re USAA General Indemnity Co." on Justia Law

The Supreme Court reversed in part the judgment of the court of appeals holding that limitations barred a mineral estate lessee's claims for injuries to its interests in one of its nine separate leases but did not bar the lessee's claims for injuries to its interests in the other eight leases, holding that the evidence did not conclusively establish that the first legal injury occurred outside the limitations period.At issue was when, for purposes of the statute of limitations, the lessee's claim that hydrogen sulfide an operator injected back into the earth migrated beneath the surface and injured the lessee's interest in the minerals underlying nearby properties accrued. The trial court concluded that the lessee's claims occurred at least two years before the lessee first filed them and were therefore untimely. The court of appeals reversed in part. The Supreme Court reversed, holding that Defendant did not establish a right to summary judgment based on limitations. View "Regency Field Services LLC v. Swift Energy Operating LLC" on Justia Law

The Supreme Court conditionally granted a petition for a writ of mandamus directing the trial court to vacate its order granting a motion to strike a counteraffidavit served under Tex. Civ. Prac. & Rem. Code 18.001 and precluding the offering party from contesting the reasonableness of the subject medical expenses at trial, holding that the trial court abused its discretion.In granting the motion to strike, the trial court concluded that the counteraffidavit failed to comply with the requirements of section 18.001. The court then prohibited the offering party from testifying regarding the reasonableness and necessity of the medical bills. Petitioner petitioned the Supreme Court for a writ of mandamus. The Supreme Court conditionally granted relief, holding that the trial court erred by striking the counteraffidavit and by granting relief that found no legal basis in section 18.001 for the purported failure to comply with the statute. View "In re Allstate Indemnity Co." on Justia Law

The Supreme Court reversed in part the judgment of the court of appeals in this premises liability case, holding that volunteers working in a third-party vendor's booth at a festival were licensees and not invitees of the landowner.Plaintiffs were the parents of four teenage volunteers at the San Lorenzo Church's annual festival. The teenagers were injured when a fire broke out in the interior of the booth they were working in. The trial court rendered a take-nothing judgment on the jury's verdict failing to find that the Church negligently caused the volunteers' injury or that the Church controlled the injury-causing activity. The court of appeals reversed, holding that the volunteers were the Church's invitees as a matter of law and that the verdict for the Church was against the preponderance of the evidence. The Supreme Court reversed, holding (1) the volunteers were licensees of the Church rather than invitees; and (2) Plaintiffs did not show either that the evidence conclusively established that the Church breached its duty to the volunteers as licensees or that the trial court otherwise committed reversible error. View "Catholic Diocese of El Paso v. Porter" on Justia Law

The Supreme Court reversed the judgment of the court of appeals denying Defendants' motion to dismiss under the Texas Citizens Participation Act (TCPA), Tex. Civ. Proc. & Rem. Code 27.001-.011, as untimely, holding that because Plaintiff's amended petition in this case asserted new legal claims, Defendants' motion to dismiss those claims was timely.In his original petition, Plaintiff asserted claims for deceptive trade practice, negligence, and negligent misrepresentation. Plaintiff subsequently filed an amended petition reasserting the same claims, adding new claims for fraud, conspiracy to commit fraud, fraudulent concealment, and breach of contract, and alleging the same essential facts alleged in the original petition and requesting the same relief. The trial court denied Defendants' TCPA dismissal motion, concluding that the motion was untimely. The court of appeals affirmed. The Supreme Court reversed, holding that the court of appeals erred in holding that Defendant's motion to dismiss the new claims was untimely because the amended petition asserted new legal actions and thus triggered new sixty-day period for Defendants to file a motion to dismiss those new claims. View "Monteglongo v. Abrea" on Justia Law

In this ad valorem tax dispute, the Supreme Court reversed the judgment of the court of appeals and the trial court declining to dismiss a tax appeal under the Texas Citizens Participation Act (TCPA), Tex. Civ. Proc. & Rem. Code 27.001-.011, holding that the motion to dismiss was timely filed.Certain taxing units sought judicial review of a tax appraisal review board order declining to reappraise the value of mineral-interest property claimed to be undervalued on the tax rolls. The trial court and court of appeals refused to dismiss the tax appeal under the TCPA. The affected taxpayer appealed, arguing that, contrary to the rulings of the lower courts, the TCPA dismissal motion was timely and the trial court had jurisdiction over the tax appeal. The Supreme Court reversed, holding (1) there was no jurisdictional impediment to reaching the merits of this appeal; and (2) the TCPA motion to dismiss was timely filed. View "Kinder Morgan SACROC, LP v. Scurry County" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the judgment of the trial court terminating Parents' parental rights to their two children, holding that the trial court remained vested with jurisdiction over the suit when it entered the final decree.In their appeal, Parents argued that the trial court's final decree terminating their parental rights was void because the trial on the merits did not commence before the dismissal date and because Tex. Fam. Code 263.401 divested the trial court of jurisdiction before the final degree was signed. The court of appeals held that the final decree was void because the trial court did not timely commence trial on the merits, thus stripping the court of jurisdiction. The Supreme Court reversed, holding that, under the facts and circumstances of this case, the trial court had jurisdiction when it entered the final decree. View "In re G.X.H." on Justia Law

The Supreme Court affirmed the portion of the judgment of the court of appeals reversing the judgment of the trial court granting a motion to reconsider the court's denial of a motion to seal brought under Tex. R. Civ. P. 76a, holding that the Texas Uniform Trade Secrets Act (TUTSA), Tex. Civ. Proc. & Rem. Code 134A.006a, does not provide an independent, self-contained pathway for sealing court records.Plaintiff sued Defendant for breach of contract, and Defendant asserted counterclaims, including misappropriation of trade secrets. The jury found in favor of Defendant. Defendant subsequently filed a Rule 76a motion to seal thirty trial exhibits. The trial court denied the motion to seal but then granted Defendant's motion to reconsider that relied exclusively on section 134A.006a of TUTSA. The Supreme Court remanded this case to the trial court to exercise its discretion under the applicable provisions of both TUTSA and Rule 76a, holding that the trial court erred by failing to apply the non-displaced provisions of Rule 76a in ruling on the motion to reconsider. View "HouseCanary, Inc. v. Title Source, Inc." on Justia Law