Justia Texas Supreme Court Opinion Summaries

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

The case revolves around a program proposed by Harris County, Texas, known as "Uplift Harris." The program aimed to provide $500 monthly cash payments to 1,928 Harris County residents for 18 months, with recipients chosen by lottery from applicants with income below 200% of the federal poverty line living in certain zip codes. The State of Texas challenged the program, arguing that it violated the Texas Constitution’s prohibition on gratuitous payments to individuals.The State sued the County, seeking an injunction to block the implementation of the program. The district court denied the State's request for a temporary injunction, leading the State to appeal this decision and request a stay of payments under the Uplift Harris program while the appeal was ongoing. The court of appeals denied this request, prompting the State to seek mandamus relief in the Supreme Court of Texas.The Supreme Court of Texas granted the State's motion for temporary relief, prohibiting all payments under the Uplift Harris program pending further order of the court. The court found that the State had raised serious doubt about the constitutionality of the program, and that potential violation of the Texas Constitution could not be remedied if payments were to commence while the underlying appeal proceeded. The court also noted that once the funds were distributed to individuals, they could not feasibly be recouped if it was later determined they were paid in violation of the Texas Constitution. The court concluded that temporarily preventing the expenditure of these funds while the State's appeal proceeded ensured public funds were not irrecoverably spent in violation of the Texas Constitution. The State's appeal of the denial of a temporary injunction remains pending in the court of appeals. View "In re The State of Texas" on Justia Law

The case revolves around the Public Utility Commission of Texas (PUC) and two market participants, RWE Renewables Americas, LLC and TX Hereford Wind, LLC. Following Winter Storm Uri, the Legislature amended the Public Utility Regulatory Act (PURA) to require that protocols adopted by the Electric Reliability Council of Texas (ERCOT) must be approved by the PUC before they take effect. ERCOT then adopted a revision to its protocols, which was approved by the PUC, setting the price of electricity at the regulatory maximum under Energy Emergency Alert Level 3 conditions. RWE challenged the PUC's approval order in the Third Court of Appeals, arguing that the order was both substantively and procedurally invalid.The Third Court of Appeals held that the PUC's order was both substantively invalid—because the PUC exceeded its statutory authority by setting the price of electricity—and procedurally invalid—because the PUC failed to comply with the Administrative Procedure Act’s rulemaking procedures in issuing the order.The Supreme Court of Texas reviewed the case and held that the PUC’s approval order is not a “competition rule[] adopted by the commission” subject to the judicial-review process for PUC rules. The court found that PURA envisions a separate process for ERCOT-adopted protocols, and the statutory requirement that the PUC approve those adopted protocols does not transform PUC approval orders into PUC rules eligible for direct review by a court of appeals. Therefore, the Third Court of Appeals lacked jurisdiction over this proceeding. The Supreme Court of Texas vacated the court of appeals’ judgment and dismissed the case for lack of jurisdiction. View "Public Utility Commission v. RWE Renewables Americas, LLC" on Justia Law

The case revolves around the actions of the Public Utility Commission of Texas (Commission) during Winter Storm Uri, when the Texas electric grid was on the brink of collapse. The Commission issued two orders that effectively raised the market price of electricity to the regulatory ceiling of $9,000/MWh to incentivize generators to add supply and large industrial users to reduce their demand. This led to some market participants going bankrupt and subsequent litigation.The court of appeals held that the Commission’s orders exceeded its authority under Chapter 39 of the Public Utility Regulatory Act (PURA) because the statute prohibits price-setting. The court of appeals did not address whether the Commission complied with the Administrative Procedure Act’s (APA) procedural rulemaking requirements.The Supreme Court of Texas disagreed with the court of appeals' decision. It held that the Commission’s orders did not exceed its authority under PURA. The court also found that the Commission substantially complied with the APA’s procedural rulemaking requirements, an issue the court of appeals did not address. The Supreme Court of Texas reversed the judgment of the court of appeals and rendered judgment affirming the orders. View "Public Utility Commission v. Luminant Energy Co. LLC" on Justia Law

The case revolves around a sexual harassment claim brought by Nicole Harris against her former employer, Fossil Group, Inc. Harris alleged that she was sexually harassed by an assistant store manager, Leland Brown, during her employment at a Fossil store in Frisco, Texas. The harassment primarily occurred through social media and included obscene and sexually explicit videos, photos, and messages. Harris claimed that she sent an email reporting the harassment through Fossil's anonymous reporting system in late April 2019, but received no response. She resigned from her position in early May 2019.The trial court granted Fossil's motion for summary judgment, ruling in favor of the company. The court found that there was no evidence that Fossil knew or should have known about the harassment but failed to remedy the situation. Harris appealed this decision.The Court of Appeals reversed the trial court's judgment. The appellate court held that Harris's testimony about her email was some evidence that Fossil knew or should have known about Brown's misconduct. The court also stated that Fossil took no remedial action after Harris sent the email.The Supreme Court of Texas disagreed with the Court of Appeals' decision. The court held that even if Fossil had received Harris's email, there was no evidence that its subsequent actions were not prompt and remedial. The court noted that mere days after Harris sent the email, she voluntarily resigned, and she did not identify any instances of interim harassment. The following week, the store manager reported the matter to human resources after learning about the harassment from another source. By the end of the month, Fossil had fired Brown. The court also held that Harris did not raise a fact issue that Fossil knew or should have known about the harassment before the date of the email. Therefore, the Supreme Court of Texas reversed the Court of Appeals' judgment and reinstated the trial court's judgment in favor of Fossil. View "Fossil Group, Inc. v. Harris" on Justia Law

The case revolves around a dispute between the Board of Regents of the University of Texas System and IDEXX Laboratories, Inc. over the interpretation of a patent licensing agreement. The agreement, signed in 2000, pertained to a peptide used to test for Lyme disease in dogs. The agreement stipulated different royalty rates for different types of products, depending on what tests were included. The dispute arose over the interpretation of two royalty provisions, one for 1% and the other for 2.5%, which could both be read to apply to the same sales of goods. IDEXX Laboratories had been paying the lower royalty rate, but the University argued that the higher rate should have been applied.The trial court ruled in favor of the University, concluding that the licensing agreement was clear and unambiguous and that the University was entitled to recover the unpaid royalties claimed plus accrued interest. On appeal, IDEXX Laboratories argued for the first time that the licensing agreement was ambiguous. The court of appeals agreed, concluding that both interpretations of the royalty provisions were reasonable and conflicting, and therefore the agreement was ambiguous. It reversed the trial court's decision and remanded the case.The Supreme Court of Texas disagreed with the court of appeals. It found that the royalty provisions were not ambiguous when read in the context of the licensing agreement itself and the objective circumstances in which the agreement was produced. The court concluded that the provisions were most reasonably interpreted to require royalties on IDEXX Laboratories' products at the higher rate stipulated in the agreement. The court reversed the court of appeals' judgment and remanded the case to that court for further proceedings. View "Board of Regents of the University of Texas System v. IDEXX Laboratories, Inc." on Justia Law

Roel Canales sued Pay and Save, a grocery store, for injuries he sustained after his foot got stuck in a wooden pallet used to display watermelons, causing him to fall and fracture his elbow. Canales had visited the store hundreds of times before and had purchased watermelons without incident. The wooden pallets, which have open sides to facilitate transport by forklifts and pallet jacks, are a common and necessary tool used by grocery stores to transport and display watermelons due to their size, weight, and shape.The trial court awarded Canales over $6 million in damages. The Court of Appeals for the Fourth District of Texas found the evidence legally but not factually sufficient to support the jury's findings regarding premises liability, reversed the decision, and remanded for a new trial. The court also ruled that Canales take nothing on his gross negligence claim.The Supreme Court of Texas disagreed with the Court of Appeals. It held that the evidence was legally insufficient to support both claims because the wooden pallet was not unreasonably dangerous as a matter of law. The court noted that there was no evidence of prior complaints, reports, or injuries from similar pallets, not just at Pay and Save’s 150 stores, but also at other grocery stores. The court also found no evidence of any code, law, or regulation prohibiting or restricting the use of wooden pallets. The court concluded that the wooden pallet was a common condition, a type of hazard that people encounter and avoid every day by exercising common sense, prudence, and caution. The court reversed the Court of Appeals' judgment in part and rendered judgment for Pay and Save. View "Pay and Save, Inc. v. Canales" on Justia Law

The case revolves around Pureza “Didit” Martinez, who was terminated from her position at the Texas Tech University Health Sciences Center at the age of 72. She filed a lawsuit alleging age discrimination against the Health Sciences Center, the Texas Tech University System, and the Texas Tech University System’s Board of Regents. The Texas Tech University System and the Board of Regents argued that they were not Martinez's employer and thus retained sovereign immunity.Previously, the trial court denied the plea to the jurisdiction filed by the Texas Tech University System and the Board of Regents, and the court of appeals affirmed this decision. The defendants argued that Martinez failed to plead allegations that could make them liable for age discrimination under the Labor Code, essentially denying being Martinez’s employer.The Supreme Court of Texas disagreed with the lower courts' decisions. The court found that Martinez's petition did not allege facts demonstrating that the Texas Tech University System or the Board of Regents employed Martinez directly or that either one controlled access to and interfered with her employment. Therefore, the court concluded that Martinez failed to allege a waiver of sovereign immunity, and the plea to the jurisdiction of the Texas Tech University System and the Board of Regents should have been granted. However, the court remanded the case to the trial court to give Martinez an opportunity to replead, as her petition did not foreclose a valid claim against those defendants. View "Texas Tech University System v. Martinez" on Justia Law

The case revolves around a dispute over the use of a property in the River Plantation subdivision, which has been operated as a golf course since the subdivision's establishment. The River Plantation Community Improvement Association (the Association) sought a declaratory judgment that the golf course property is encumbered by an implied reciprocal negative easement restricting it to use solely as a golf course. The owners of the golf course property, River Plantation Properties, LLC and Preisler Golf Properties, LLC, counterclaimed for a declaration that the property is not so encumbered.The trial court granted summary judgment for the golf course property’s owners, holding it is not burdened by an implied reciprocal negative easement as a matter of law. The court of appeals affirmed this decision, noting that when the subdivision was developed, the developers retained the Reserves without placing any restrictions on their use, and the recitals in the property records put prospective lot owners on notice that the Reserves were excluded from the subdivision’s uniform plan.The Supreme Court of Texas agreed with the lower courts and affirmed the court of appeals’ judgment. The court held that the doctrine of implied reciprocal negative easements does not apply in this case. The Association's complaint was not that a substantial number of lots in the River Plantation subdivision were burdened by express restrictions when originally conveyed by the developer while others were not. Instead, the Association argued that the property should be burdened by an entirely different restriction: golf course use only. The court concluded that there are no substantially uniform express restrictions on the River Plantation lots that the Association claims give rise to similar restrictions on the golf course property. Therefore, the golf course property is not burdened by an implied reciprocal negative easement. View "River Plantation Community Improvement Assn. v. River Plantation Properties, LLC" on Justia Law