Justia Texas Supreme Court Opinion Summaries

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

The Supreme Court reversed the judgment of the court of appeals reversing the judgment of the trial court upholding the determination of the Public Utility Commission that Southwestern Electric Power Company (SWEPCO) met its burden of establishing that its decision to build a power plant was a prudent one and allowing SWEPCO to include the plant's construction costs in its utility rates, holding that the court of appeals erred.In reversing, the court of appeals concluded that the Commission had used an improper standard for assessing SWEPCO's decision to complete construction of the plant and that, because SWEPCO did not produce independent expert testimony, the Commission's decision was without a proper basis. The Supreme Court reversed, holding (1) the Commission properly applied its standard in evaluating SWEPCO's decision to complete construction; and (2) substantial evidence supported the Commission's decision. View "Public Utility Commission of Texas v. Texas Industrial Energy Consumers" on Justia Law

The Supreme Court denied Relators' request for mandamus relief, holding that Tex. Gov't Code 22.004(i)'s prohibition on counter-supersedes refers to a particular procedural process, not an appellate court's temporary orders under other authority.In this ultra vires dispute, state regulators appealed an adverse temporary injunction. The trial court allowed Plaintiff, a school district, to counter-supersede the injunction so the regulators could not undertake unauthorized actions absent success on appeal. The court of appeals reversed the counter-supersedeas order, concluding that it was contrary to section 22.004(i) and Tex. R. App. P. 24.2(a)(3), but issued its own temporary order continuing the injunction pending disposition of the appeal. The Supreme Court denied mandamus relief, holding that the appellate court's temporary order did not conflict with section 22.004(i) because it was not counter-supersedes relief within the meaning of the statute. View "In re Texas Education Agency" on Justia Law

In these original proceedings arising from suits by holders of underinsured motorist (UIM) insurance seeking recovery against their insurers following traffic accidents the Supreme Court held that insureds who bring only Insurance Code claims seeking policy benefits as damages must also succeed in an initial "car crash" trial in order to lay the predicate for their statutory claims.Following traffic accidents, holders of UIM insurance sought recovery against their insurers. The insureds, however, did not sue for breach of their insurance companies and brought only extracontractual Insurance Code Claims. In both cases, State Farm filed motions for bifurcated trial under Rule 174(b). After the trial courts denied State Farm's motions, State Farm petitioned for mandamus relief. In response, Petitioners argued that because they brought only statutory claims and because there were no breach of contract claims to try first, no bifurcation of trial was required. The Supreme Court granted mandamus relief, holding that although Petitioners' claims were not labeled breach of contract Petitioners nevertheless just establish State Farm's liability under their insurance policies as a prerequisite to recovery on their Insurance Code claims. View "In re State Farm Mutual Automobile Insurance Co." on Justia Law

In this second action arising out of a joint effort by TRO-X, L.P. and Eagle Oil & Gas Co. to acquire and sell oil-and-gas the Supreme Court affirmed the judgment of the court of appeals reversing the trial court's grant of summary judgment for Eagle, holding that Eagle did not conclusively establish the affirmative defenses that were the basis of its summary judgment motion.In its first suit, TRO-X alleged that Eagle deprived TRO-X of its right to acquire its share of mineral leases that Eagle retained as part of the leases' sale. The court of appeals determined that TRO-X had not been deprived of equitable title to those interests because TRO-X had always held them. In this second suit, TRO-X claimed that Eagle failed to remit its share of income generated from production on the interests that commenced after the first trial's conclusion. The trial court granted summary judgment for Eagle, and the court of appeals reversed. The Supreme Court affirmed, holding that Eagle did not conclusively establish the affirmative defenses of res judicata, statute of limitations, or waiver. View "Eagle Oil & Gas Co. v. TRO-X, L.P." on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the trial court's grant of summary judgment in favor of Insurer in this insurance dispute, holding that payment of an appraisal award does not absolve the insurer of statutory liability when an insurer accepts a claim but pays only the part of the amount it owed within the statutory deadline for payment.Homeowner reported a claim to Insurer for damage to his home. Insurer accepted Homeowner's claim and paid part of it before the statutory deadline. Dissatisfied with the amount, Homeowner sued, seeking full payment of the claim plus interest and attorney's fees under the Teas Prompt Payment of Claims Act, Tex. Ins. Code Chapter 542. While the suit was pending but after the statutory deadline had passed, Insurer invoked the policy's appraisal process, and the appraised awarded Homeowner more than Insurer paid. Insurer paid the difference then moved for summary judgment. The trial court granted summary judgment, and the court of appeals affirmed. The Supreme Court reversed, holding that because Insurer did not pay the amount that "must be paid" before the statutory deadline, it was not entitled to summary judgment. View "Hinojos v. State Farm Lloyds" on Justia Law

The Supreme Court dismissed these two petitions - one for writ of mandamus and the other for review - arising from a lawsuit that thirteen Panda Power companies (collectively, Panda) filed against the Electric Reliability Council of Texas, Inc. (ERCOT), holding that this Court lacked jurisdiction to hear the petitions.Panda sued ERCOT and three of its officers for fraud, negligent misrepresentation, and breach of fiduciary duty. ERCOT filed a plea to the jurisdiction, arguing that the Public Utility Commission had exclusive jurisdiction over Panda's claims. The trial court denied the motion. ERCOT appealed and, as an alternative, filed a petition for a writ of mandamus, arguing that sovereign immunity barred Panda's claims. The court of appeals (1) dismissed ERCOT's interlocutory appeal for want of jurisdiction, holding that ERCOT was not a governmental unit under the Tort Claims Act; but (2) granted ERCOT's mandamus petition, holding that sovereign immunity applied and barred Panda's claims. The Supreme Court dismissed both the mandamus petition and the petition for review, holding that the trial court's entry of a final judgment rendered this causes arising from the interlocutory order moot. View "In re Panda Power Infrastructure Fund, LLC" on Justia Law