Justia Texas Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals with respect to Plaintiff's constitutional claims, holding that a state university's dismissal of a student for poor academic performance does not implicate a liberty or property interest protected by the Texas Constitution's guarantee of due course of law.Plaintiff was dismissed from Texas Southern University's Thurgood Marshall School of Law after one year due to his failure to maintain the required grade point average. Plaintiff brought this suit against the School, alleging breach of contract and deprivation of his property and liberty without due course of law. The trial court granted the School's plea to the jurisdiction invoking sovereign immunity. The court of appeals reversed in part, concluding that Plaintiff's procedural and substantive due course of law claims were viable. The Supreme Court reversed in part and rendered judgment dismissing the case, holding that an academic dismissal from higher education does not implicate a protected liberty interest. View "Texas Southern University v. Villarreal" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the orders of the trial courts in these three cases brought by downstream property owners asserting that the San Jacinto River Authority's release of water from its Lake Conroe reservoir into the San Jacinto River caused or contributed to the flooding of their properties, holding that the trial court did not err by denying the River Authority's motions to dismiss the three suits.Plaintiffs asserted both common-law inverse condemnation claims under Tex. Const. art. I, 17 and statutory takings claims under Chapter 2007 of the Government Code. The River Authority moved to dismiss the three suits, arguing that Chapter 2007 applied strictly to regulatory takings and not physical takings, as Plaintiffs contended. The trial court denied the motions to dismiss. The court of appeals affirmed, holding that Chapter 2007's statutory takings claim included the physical takings claim alleged in the property owners' pleadings. The Supreme Court affirmed, holding that the statutory takings claim may include a physical taking and is not limited solely to regulatory takings. View "San Jacinto River Authority v. Argento" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the trial court's grant of summary judgment for Defendants in this trespass to try title suit, holding that the trial court properly granted summary judgment for Defendants.Plaintiff and Defendants were lessees of adjacent mineral estates. Plaintiff brought this suit alleging that Defendants drilled several wells either on Plaintiff's leasehold or closer to the lease line that allowed by Railroad Commission rules. Defendants claimed that Plaintiff ratified the boundary line through a boundary stipulation between the fee owners of the two mineral estates and Plaintiff's written acceptance of the stipulation, thus foreclosing the trespass claims. The trial court granted summary judgment for Defendants. The court of appeals reversed, concluding that the boundary stipulation was void and therefore could not be ratified. The Supreme Court reversed, holding (1) the boundary stipulation was valid; and (2) Defendants conclusively established their ratification defense. View "Concho Resources, Inc. v. Ellison" on Justia Law

In this products liability action, the Supreme Court affirmed the judgment of the court of appeals affirming the judgment of the trial court against Petitioners, holding that legally sufficient evidence supported the jury's design-defect findings and that the trial court's jury instructions did not cause an improper verdict.An electric terminal manufacturer made two terminals for essentially the same cost, but the older of the two designs was more susceptible to failure. A corporate affiliate of the terminal maker decided to use the older product in manufacturing new air conditioning compressors. When an experienced HVAC technician purchased and installed a compressor containing the older terminal design, the compressor became overheated and the terminal emitted scalding pressurized fluids that ignited and covered the technician. The technician, who received serious burns, brought this action. The jury found that the older terminal design was unreasonably dangerous and that both the design and the failure warn caused the technician's injuries. The court rendered judgment on the jury's verdict. The Supreme Court affirmed, holding that there was no error in the proceedings below. View "Emerson Electric Co. v. Johnson" on Justia Law

The Supreme Court granted Petitioner's petition for writ of habeas corpus and ordered that Petitioner is and shall remain discharged from custody, holding that the subject temporary restraining order's lack of specificity regarding the conduct to be restrained rendered it and the judgment of contempt and order of confinement void.Petitioner was jailed and her solely-owned business, a cosmetology salon, was fined for violating a temporary restraining order requiring them to cease and desist for operating the salon for in-person services in violation of regulations related to the COVID-19 pandemic. The trial court issued a judgment holding Petitioner and her business in contempt. Petitioner filed this habeas corpus petition arguing that she was illegally restrained because the temporary restraining order was unconstitutional and void. The Supreme Court agreed, holding (1) the temporary order was void; and (2) therefore, the contempt judgment based on that order was void as well. View "In re Luther" on Justia Law

In this contract dispute involving the correct interpretation of a mineral lease's "continuous drilling program" provision the Supreme Court held that the court of appeals erred in reversing partial summary judgment for the lessee on the contract-construction issue.Lessor and Lessee were the successors-in-interest to an oil-and-gas top lease covering a 30,450-acre parcel of land. At the end of the primary term, Lessee was required to reassign to Lessor all of Lessee's operating rights in each tract of the lease not then held by production unless Lessee was engaged in a "continuous drilling program." Notwithstanding Lessee's continued drilling operations, Lessor filed a suit seeking a declaration that the lease had terminated. The trial court granted partial summary judgment for Lessor, concluding that the lease had not terminated as to non-producing tracts. The court of appeals reversed. The Supreme Court reversed, holding (1) under the lease's special definition of drilling operations, activities other than spudding-in a well are sufficient to maintain the lease as to non-producing tracts; and (2) the record conclusively established that Lessee was engaged in a continuous drilling program within the meaning of the lease. View "Sundown Energy LP v. HJSA No. 3" on Justia Law

The Supreme Court reversed in part and affirmed in part the judgment of the court of appeals concluding that Data Foundry, Inc., an internet service provider, had standing to bring its claims but affirming the trial court's dismissal of Data Foundry's claims in part on other grounds, holding that the court of appeals erred by affirming portions of the trial court's judgment.The City of Austin sets the rates that Austin Energy, an electric utility owned by the City, charged to Austin residents for retail electric services. Data Foundry, which purchased electricity from Austin Energy, brought this action alleging that the rates charged by the City were illegal. The trial court granted the City's motion to dismiss on the ground that Data Foundry lacked standing because it failed to allege it had suffered a particularized injury. The court of appeals affirmed the dismissal on other grounds. The Supreme Court remanded all of Data Foundry's claims to the trial court for further proceedings, holding (1) Data Foundry had standing to bring its claims; (2) the court of appeals correctly reversed the dismissal of some of Data Foundry's claims, including its common-law and constitutional claims; and (3) the court of appeals erred by affirming portions of the trial court's judgment on other grounds. View "Data Foundry, Inc. v. City of Austin" on Justia Law

In this long-running class action suit, the Supreme Court reversed in part and affirmed in part the decision of the court of appeals affirming the district court's grant of summary judgment in favor of Insureds but reversing the portion of the judgment ordering Insurer to issue the disputed insurance policies at a determined premium, holding that Insurer correctly interpreted the subject policy.At issue was how to interpret a homeowners insurance policy that had been out of use for almost twenty years. Insurer sent a notice of non-renewal to its insurers that it had decided to stop offering broad "all-risk" policies. Plaintiff, on behalf of herself and a class of similarly situated people, brought this suit seeking a declaratory judgment that the non-renewal was effective and that class members were entitled to renew their all-risk policies. The trial court granted summary judgment to Plaintiff and the class. The court of appeals affirmed in part and reversed in part. The Supreme Court reversed in part, holding that Insurer was entitled to summary judgment on the breach of contract claim for non-renewal of the policies and that remand was required for the trial court to address any remaining matters. View "Farmers Group, Inc. v. Geter" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the decision of the trial court concluding that indemnity claims fell within an exception to an arbitration clause and that the non-signatory assignees were bound by the agreement under a theory of assumption, holding that Plaintiffs' request for a declaratory judgment was subject to mandatory arbitration.As president of Wagner Oil Company, Bryan Wagner signed a purchase and sale agreement (PSA) purchasing several assets from Apache Corporation. The PSA contained an indemnification provision and an arbitration clause. Later, third-party surface landowners filed lawsuits against Apache, seeking damages for alleged environmental contamination caused by Apache's operation of the assets before they were sold. Apache filed a demand for arbitration against Plaintiffs, including Wagner Oil and Wagner, for indemnity and defense. Plaintiffs then filed a declaratory judgment action seeking a declaration that Plaintiffs were not parties to the PSA and therefore not subject to the arbitration and indemnity clauses. The trial court denied Apache's motion to compel arbitration. The court of appeals reversed. The Supreme Court affirmed, holding (1) the indemnity disputes over third party-claims fall within the scope of the arbitration clause and outside its exception; and (2) the Wagner Oil signees were bound by the arbitration clause. View "Wagner v. Apache Corp." on Justia Law

The Supreme Court affirmed the judgment of the court of appeals finding a property owner liable for injuries the employees of its contractor sustained while working on the property, holding that the employees established their claim.A jury found the property owner under both premises-liability and ordinary-negligence theories. The court of appeals affirmed the trial court's judgment in favor of the employees. On appeal, the property owner argued that the employees failed to submit legally sufficient evidence and failed to obtain the findings necessary to establish liability under chapter 95 of the Texas Civil Practice and Remedies Code. The Supreme Court affirmed, holding (1) chapter 95 applied to the employees' negligence claims; and (2) the evidence and jury findings supported the judgment against the property owner. View "Los Compadres Pescadores, LLC v. Valdez" on Justia Law