Justia Texas Supreme Court Opinion Summaries

This case involves a dispute over a provision in a collective bargaining agreement between the City of Austin and the Austin Firefighters Association. The provision, known as Article 10, grants 5,600 hours of "Association Business Leave" (ABL) annually for firefighters to conduct union-related activities. The petitioners, including the State of Texas and several individuals, argued that Article 10 violates the "Gift Clauses" of the Texas Constitution, which prohibit governmental entities from making gifts of public resources to private parties. They contended that the ABL provision improperly benefits the union by allowing firefighters to use paid time off for union activities, some of which they alleged were misused for improper purposes.The case was initially dismissed under the Texas Citizens Participation Act (TCPA), with the trial court granting relief to the Association, including the award of fees and sanctions. On appeal, the trial court's findings of fact went unchallenged, and the focus was primarily on whether the agreement itself violated the Gift Clauses.The Supreme Court of Texas held that Article 10 does not violate the Gift Clauses. The court found that the provision is not a gratuitous gift but brings a public benefit, serves a legitimate public purpose, and the government retains control over the funds to ensure that the public purpose is achieved. The court emphasized that the ABL must be used for activities that directly support the mission of the Fire Department or the Association and are consistent with the Association’s purposes. The court also reversed the trial court's order granting the Association's TCPA motion to dismiss and its award of sanctions and fees against the original plaintiffs. View "BORGELT v. AUSTIN FIREFIGHTERS ASSOCIATION, IAFF LOCAL 975" on Justia Law

The case involves Dianne Hensley, a justice of the peace in Texas, who announced that due to her religious beliefs, she would not perform weddings for same-sex couples but would refer them to others who would. The State Commission on Judicial Conduct issued her a public warning for casting doubt on her capacity to act impartially due to the person's sexual orientation, in violation of Canon 4A(1) of the Texas Code of Judicial Conduct. Hensley did not appeal this warning to a Special Court of Review (SCR) but instead sued the Commission and its members and officers for violating the Texas Religious Freedom Restoration Act (TRFRA) and her right to freedom of speech under Article I, Section 8 of the Texas Constitution. The trial court dismissed her claims for lack of jurisdiction, and the court of appeals affirmed.The Supreme Court of Texas held that Hensley's suit was not barred by her decision not to appeal the Commission’s Public Warning or by sovereign immunity. The court affirmed the part of the court of appeals’ judgment dismissing one of Hensley's declaratory requests for lack of jurisdiction, reversed the remainder of the judgment, and remanded to the court of appeals to address the remaining issues on appeal. The court found that the SCR could not have finally decided whether Hensley is entitled to the relief sought in this case or awarded the relief TRFRA provides to successful claimants. View "HENSLEY v. STATE COMMISSION ON JUDICIAL CONDUCT" on Justia Law

The case involves a dispute between Mary Alice Keyes and Sean Leo Nadeau, who are the owners and agents of MonoCoque Diversified Interests, LLC, and David Weller, who provides aviation consulting services through his company, IntegriTech Advisors, LLC. Weller was discussing a potential employment relationship with MonoCoque. After several discussions and email exchanges outlining the agreed terms, Weller accepted MonoCoque’s offer and began working for them. However, disagreements arose over the terms of Weller's compensation, leading to Weller's resignation. Weller and IntegriTech sued MonoCoque, Keyes, and Nadeau, asserting various fraud claims and a Texas Securities Act claim against all three defendants.The defendants argued that they were shielded from liability by Section 21.223 of the Texas Business Organizations Code because they were acting as agents of the company and there was no evidence that they were seeking a direct personal benefit. The trial court granted the defendants' motion for partial summary judgment on the fraud claims. On appeal, the court of appeals reversed the trial court’s decision, holding that Section 21.223 does not abrogate the common law principle that individuals are directly liable for their own tortious conduct, even if committed in the course and scope of their employment.The Supreme Court of Texas affirmed the judgment of the court of appeals. The court held that Section 21.223 does not limit an individual’s liability under the common law for tortious acts allegedly committed while acting as a corporate officer or agent, even when the individual is also a shareholder or member. The court concluded that the trial court erred in granting summary judgment on the fraud claims against Keyes and Nadeau and remanded the case to the trial court for further proceedings. View "KEYES v. WELLER" on Justia Law

The case involves a products liability action against American Honda Motor Co., Inc. (Honda) for an alleged negligent design of a seat-belt system in a 2011 Honda Odyssey. The plaintiff, Sarah Milburn, was severely injured in a car accident while riding in an Uber vehicle, a 2011 Honda Odyssey. Milburn was seated in the third-row middle seat, which had a ceiling-mounted detachable Type 2 anchor system for the seat belt. Milburn fastened her seat belt incorrectly, leaving her lap unbelted. The accident resulted in Milburn becoming a quadriplegic.The trial court rendered judgment in favor of Milburn based on the jury's verdict, and the court of appeals affirmed. The court of appeals held that legally sufficient evidence supported the jury’s findings that the presumption of nonliability applied and that the presumption was rebutted.The Supreme Court of Texas reversed the court of appeals’ judgment. The court held that the presumption of nonliability applied as a matter of law because the 2011 Odyssey’s design complied with mandatory federal safety standards that were applicable to the Odyssey at the time of manufacture and governed the product risk that allegedly caused harm. The court further held that the presumption was not rebutted, as no evidence supports the jury’s finding that the federal safety standards failed to adequately protect the public from unreasonable risks of injury. Therefore, the court rendered a take-nothing judgment for Honda. View "AMERICAN HONDA MOTOR CO., INC. v. MILBURN" on Justia Law

The case involves Ammonite Oil & Gas Corporation (Ammonite) and the Railroad Commission of Texas and EOG Resources, Inc. (EOG). Ammonite leases mineral rights beneath a riverbed from the State of Texas. EOG leases the minerals on the land adjoining the river on both sides. All the minerals in the area lie in a common subsurface reservoir. EOG's wells, however, do not reach the minerals beneath the riverbed. Ammonite argued that without pooling, its minerals are left stranded. Ammonite applied to the Railroad Commission for forced pooling under the Texas Mineral Interest Pooling Act (MIPA).The Railroad Commission rejected Ammonite's applications to force-pool the minerals beneath the river—which are not being produced—with those beside it—which are. The lower courts affirmed the Commission’s order. The Supreme Court of Texas also affirmed the lower courts' decisions but for different reasons than the court of appeals gave.The Supreme Court of Texas held that the Commission’s conclusion that “Ammonite failed to make a fair and reasonable offer to voluntarily pool as required by [MIPA Section] 102.013” is reasonable. The court also held that Ammonite has failed to show that forced pooling of its acreage with EOG’s wells is necessary to prevent its minerals from ultimately being lost. The court concluded that Ammonite applied for a share of EOG’s revenue without contributing to it and that the Commission’s conclusion that forced pooling would not prevent waste or protect correlative rights is not unreasonable. View "AMMONITE OIL & GAS CORPORATION v. RAILROAD COMMISSION OF TEXAS" on Justia Law

The case involves Angela Horton and Kevin Houser, who sued the Kansas City Southern Railway Company (KC Southern) for the wrongful death of their mother. They alleged that KC Southern negligently maintained a railroad crossing by raising the crossing grade over time to form a “humped crossing” and by failing to replace a missing yield sign. The jury found both parties negligently caused the accident and assigned equal responsibility to each. The trial court awarded Horton fifty percent of the damages. The court of appeals reversed the judgment and remanded for a new trial, holding that federal law preempts a negligence claim based on the humped crossing, but supports a finding that the missing yield sign proximately caused the accident.The Supreme Court of Texas affirmed the court of appeals’ judgment, but on different grounds. The court held that federal law does not preempt the humped-crossing claim and that no evidence supports the jury’s finding that the absence of the yield sign proximately caused the accident. The court concluded that only one of the two allegations could support the jury’s negligence finding, and it could not be certain which of the two allegations the jury relied on. Therefore, the court agreed with the court of appeals that the trial court’s use of a broad-form question to submit the negligence claim constituted harmful error and that a new trial is required. However, the court remanded for a new trial on the humped-crossing allegation rather than on the missing-yield-sign allegation. After further review, the court reversed its previous decision and reinstated the trial court’s judgment, concluding that the submission of the broad-form question did not constitute harmful error. View "HORTON v. THE KANSAS CITY SOUTHERN RAILWAY COMPANY" on Justia Law

In two consolidated property tax disputes, Oncor Electric Delivery Company NTU, LLC sought a multimillion-dollar reduction in the total values of certain electric transmission lines in the 2019 certified appraisal rolls for the Wilbarger County Appraisal District and Mills Central Appraisal District. Oncor’s predecessor had agreed to the lines’ value in each county to settle its protests of the Districts’ initial appraised values, but Oncor now contends that these agreements are void due to mutual mistake.Previously, Oncor filed unsuccessful motions for correction of the appraisal rolls with each County Appraisal Review Board (ARB) and then sued in district court in Wilbarger and Mills Counties. The trial and appellate courts below provided conflicting answers on whether questions regarding the effect of a Section 1.111(e) agreement—such as its validity and scope—are relevant to a trial court’s subject-matter jurisdiction over a suit for judicial review under Section 42.01 of the Tax Code.The Supreme Court of Texas held that the resolution of such questions does not implicate jurisdiction and remanded the cases to the trial courts for further proceedings. The court did not reach the merits of the parties’ disputes about whether Oncor has identified errors eligible for correction under Sections 25.25(c) or (d) of the Tax Code, whether any such errors fall within the scope of the parties’ Section 1.111(e) settlement agreements, and whether the doctrine of mutual mistake is an available defense to such agreements. View "MILLS CENTRAL APPRAISAL DISTRICT v. ONCOR ELECTRIC DELIVERY COMPANY NTU LLC" on Justia Law

This case involves a dispute over the interpretation of a statute that regulates healthcare providers participating in the federal Medicaid program. The State of Texas, acting through the Attorney General, sought to enforce a statute that imposes penalties on a provider who submits a claim for payment and knowingly fails to indicate the type of professional license and the identification number of the person who actually provided the service. The defendant, a dentist, argued that the statute only applies if a claim fails to indicate both the license type and the identification number of the actual provider.Previously, the trial court granted the State's motion for partial summary judgment and denied the defendant's motion. The court rendered a final judgment awarding the State more than $16,500,000. The defendant appealed, and the court of appeals affirmed the trial court's judgment, except for the amount of attorney’s fees and expenses.The Supreme Court of Texas reversed the lower courts' decisions. The court agreed with the defendant's interpretation of the statute. The court held that the statute applies only if a claim fails to indicate both the license type and the identification number of the actual provider. The court found that the 1,842 claims at issue did indicate the actual providers’ license type, so they did not constitute an unlawful act under the statute. The court rendered judgment in the dentist’s favor. View "MALOUF v. THE STATE OF TEXAS EX RELS. ELLIS AND CASTILLO" on Justia Law

The case revolves around a tax appraisal dispute involving Texas Disposal Systems Landfill, Inc. (the Landfill) and Travis Central Appraisal District (the District). The Landfill owns 344 acres of land in Travis County, which it operates as a landfill. In 2019, the District appraised the market value of the landfill at $21,714,939. The Landfill protested this amount under the Tax Code provision requiring equal and uniform taxation but did not claim that the District’s appraised value was higher than the market value of the property. The appraisal review board reduced the appraised value of the subject property by nearly ninety percent. The District appealed to the trial court, claiming that the board erred in concluding that the District’s appraised value was not equal and uniform when compared with similarly situated properties. The District also claimed that the board’s appraised value was lower than the subject property’s true market value.The trial court granted the Landfill’s plea to the jurisdiction, arguing that the challenge it made before the appraisal review board was an equal-and-uniform challenge, not one based on market value. Thus, the trial court lacked jurisdiction to consider market value. However, the court of appeals reversed this decision, holding that a trial court’s review of an appraisal review board’s decision is not confined to the grounds the taxpayer asserted before the board.The Supreme Court of Texas affirmed the court of appeals' judgment. The court concluded that the Tax Code limits judicial review to conducting a de novo trial of the taxpayer’s protest. In deciding the taxpayer’s protest in this case, the trial court is to determine the equal and uniform appraised value for the property subject to taxation. This limit, though mandatory, is not jurisdictional. The case was remanded to the trial court for further proceedings. View "TEXAS DISPOSAL SYSTEMS LANDFILL, INC. v. TRAVIS CENTRAL APPRAISAL DISTRICT" on Justia Law

The case involves Image API, LLC, a company that provided services to the Texas Health and Human Services Commission (HHSC) from 2009 to 2015. Image's job was to manage a processing center for incoming mail related to Medicaid and other benefits programs. The agreement between the parties stated that HHSC would compensate Image using its “retrospective cost settlement model”. In 2016, HHSC notified Image that an independent external firm would conduct an audit of Image’s performance and billing for the years 2010 and 2011. The audit concluded that HHSC had overpaid Image approximately $440,000 in costs relating to bonuses, holiday pay, overtime, and other unauthorized labor expenses. HHSC then sought to recoup the overpayments by deducting from payments on Image’s invoices.The trial court granted HHSC’s motion for summary judgment and signed a final judgment for the commissioner. The court of appeals reversed the trial court’s judgment and dismissed Image’s entire suit for want of jurisdiction. Image sought review.The Supreme Court of Texas held that Image is a Medicaid contractor under Section 32.0705(a), and that the deadline in Section 32.0705(d) for auditing HHSC’s Medicaid contractors is mandatory. However, the court ruled that HHSC’s failure to meet the deadline does not preclude it from using the result of the audit or pursuing recoupment of overcharges found in the audit. The court affirmed the part of the court of appeals’ judgment dismissing Image’s claims arising from the 2016 audit for lack of jurisdiction, reversed the part of the judgment dismissing the remainder of Image’s suit, and remanded to the trial court for further proceedings. View "IMAGE API, LLC v. YOUNG" on Justia Law