Justia Texas Supreme Court Opinion Summaries

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

The Supreme Court reversed the decision of the court of appeals reversing the judgment of the trial court granting summary judgment for Defendant in this workers' compensation case, holding that Plaintiff qualified as Defendants' employee under the Workers' Compensation Act, and therefore, the Act's exclusive remedy provision barred Plaintiff's claims.Plaintiff was an employee of a temporary staffing agency when he was injured while on assignment to a client of the agency. The staffing agency provided workers' compensation benefits. Plaintiff then sued Defendant, the client for whom he performed the work, alleging common-law negligence. The trial court granted summary judgment in favor of Defendant. The court of appeals reversed. The Supreme Court reversed, holding that summary judgment for Defendant was appropriate. View "Waste Management of Texas, Inc. v. Stevenson" on Justia Law

The Supreme Court conditionally granted mandamus relief in these actions challenging rulings on a Rule 91a motion to dismiss, holding that the the trial court abused its discretion in denying Insurer's motion to dismiss Insured's claim for negligent failure to settle.A liability insurer (Insurer) settled claims against its insured (Insured) within policy limits but obtained a release that was contingent on Insured paying a portion of the settlement. Insured paid and then brought this action seeking reimbursement, alleging claims for negligent failure to settle and for breach of contract. Insurer filed a motion to dismiss, which the trial court denied. Insurer sought mandamus relief. The court of appeals granted relief as to the breach of contract claim but concluded that the trial court properly refused to dismiss the claim for negligent failure to settle. Both parties sought mandamus relief. The Supreme Court conditionally granted mandamus relief to both parties, holding (1) the trial court abused its discretion in denying Insurer's motion to dismiss Insured's Stowers claim for negligent failure to settle; and (2) the court of appeals erred in ordering the trial court to dismiss Insured's claim for breach of the contractual obligation to indemnify. View "In re Farmers Texas County Mutual Insurance Co." on Justia Law

In this interlocutory appeal concerning two jurisdictional challenges the City of Houston made to this suit brought by the Texas Propane Gas Association (TPGA) seeking a declaratory judgment that the City's ordinances regulating the liquefied petroleum gas industry to include imposing criminal fines for violations were preempted by state law, the Supreme Court held that the trial court did not lack jurisdiction on either ground asserted by the City.In challenging the court's jurisdiction the City argued (1) civil courts lacked subject matter jurisdiction to adjudicate TPGA's preemption claim because the local regulations it challenges carry criminal penalties, and (2) TPGA could challenge only those regulations that had injuries at least one of its members. The trial court refused to dismiss the matter for lack of jurisdiction. The Supreme Court held (1) TPGA's claim was not a criminal law matter that must be raised in defense to prosecution; and (2) TPGA's second argument, while framed as a challenge to TPGA's standing, was really a merits challenge, and TPGA demonstrated standing to bring its preemption claim. View "Texas Propane Gas Ass'n v. City of Houston" on Justia Law

The Supreme Court held that claims pleaded under 42 U.S.C. 1983 that were asserted against a state mental health facility and its employees arising from the death of a patient are health care liability claims subject to the Texas Medical Liability Act (TMLA) and that section 1983 does not preempt the TMLA's expert report requirement.Plaintiff sued Rio Grande State Center (RGCS) and ten individual defendants after his son died in RGSC's care. As to RGSC, Plaintiff alleged negligence, and as to the individual defendants, Plaintiff asserted claims under 42 U.S.C. 1983. Defendants moved to dismiss the claims for failure to serve an expert report under Tex. Civ. Prac. & Rem. Code 74.351(b). The trial court denied the motion to dismiss, and Plaintiff nonsuited the negligence claim against RGSC. The court of appeals affirmed, holding that the expert report requirement of the TMLA was preempted by section 1983. The Supreme Court reversed, holding (1) Plaintiff's claims were health care liability claims subject to the TMLA; and (2) section 1983 does not preempt the TMLA's expert-report requirement. View "Rogers v. Bagley" on Justia Law

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