Justia Texas Supreme Court Opinion Summaries

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

The Supreme Court conditionally granted mandamus relief in this arbitration dispute, holding that the trial court abused its discretion in determining that pre-arbitration discovery was warranted in this case.After Plaintiff's employment was terminated she sued Defendant, her former employer, claiming discrimination and retaliation. Defendant moved to compel arbitration pursuant to the company's employee handbook acknowledgment and agreement, which contained an arbitration agreement. At issue was Plaintiff's second motion to compel pre-arbitration discovery claiming that an enforceable arbitration agreement did not exist. After the trial court granted the motion Defendant sought mandamus relief. The court of appeals denied the motion. The Supreme Court conditionally granted mandamus relief, holding that the trial court clearly abused its discretion in ordering pre-arbitration discovery because Plaintiff failed to provide the trial court with a reasonable basis to conclude that it lacked sufficient information to determine whether her claims were arbitrable. View "In re Copart, Inc." on Justia Law

In this appeal of a no-answer default judgment in a divorce case the Supreme Court reversed the judgment of the court of appeals affirming the trial court's judgment, holding that the trial court erred in denying Husband's motion for new trial because the content of Husband's affidavit was sufficient to satisfy the standard set forth under Craddock v. Sunshine Bus Lines, Inc., 133 S.W.2d 124 (Tex. 1939).After Husband defaulted, he filed a motion for new trial, arguing that equitable grounds existed under the Craddock standard and that legal grounds existed regarding improper service or notice of suit. The trial court sustained a hearsay objection to Husband's affidavit and other documents filed with his motion and then denied the new trial. The appellant court affirmed, concluding that formal defects rendered the affidavit inadmissible as sworn testimony, and therefore, Husband possessed insufficient proof of the required elements of Craddock. The Supreme Court reversed, holding (1) Husband's affidavit was sufficient to satisfy the Craddock standard for obtaining a new trial; (2) the affidavit was not based on hearsay; and (3) because no formal defects were raised in the trial court, the appellate court erred in affirming based on a formal defect that was not preserved for review. View "In re Marriage of Sandoval" on Justia Law

The Supreme Court affirmed in part and reversed in part the trial court's decision resolving all issues in this oil and gas dispute favorably to the lessors of a mineral lease and awarding damages for underpayment of royalties, holding that remand was required to determine damages, if any, for off-premises compressor-fuel use.One lease provision in this case required the lessee to "compute and pay royalties on the gross value received." The other lease provision at issue required royalties to be "computed at the end of the mouth of the well." The Supreme Court affirmed the lower courts' judgments except as to the portion of the judgment awarding damages for royalties on compressor fuel, holding (1) the lower courts correctly concluded that the lessee's deduction of postproduction costs was in error because the mineral lease explicitly resolved the conflict in favor of a gross-proceeds calculation; and (2) because the compressor-fuel damages were not conclusively established in the amount awarded, remand was required. View "BlueStone Natural Resources II, LLC v. Randle" on Justia Law

The Supreme Court conditionally granted the petition for a writ of mandamus filed by Gilberto Gonzales challenging a trial court order allowing Houston Distributing Company to designate an unknown person as a responsible third party, holding that Gonzales was entitled to relief.Gonzales sued Houston Distributing, alleging that it negligently caused an automobile accident. One hundred and thirty-five days after filing its answer, Houston Distributing filed a motion for leave to designate an unknown person as a responsible third party. The trial court granted the motion. Gonzales petitioned the Supreme Court for relief, challenging the order. The Supreme Court conditionally granted relief and directed the trial court to vacate its order granting Houston Distributing's motion to designate "John Doe" as an unknown responsible third party, holding that the trial court failed properly to apply Tex. Civ. Proc. & Rem. Code 33.004 and abused its discretion by granting Houston Distributing's motion for leave to designate John Doe as an unknown responsible third party. View "In re Gilberto Gonzales" on Justia Law

The Supreme Court conditionally granted a petition for writ of mandamus and directed the Austin City Council to delete the word "anyone" from a proposed ordinance before placing it on the ballot, holding that Relators clearly established their entitlement to mandamus relief in one respect.The council's ballot language said the proposed ordinance created a criminal offense and penalty for anyone sitting or lying down on a public sidewalk or sleeping outdoors in or near downtown and for anyone camping in a public area not designated by the Parks and Recreation Department. The ordinance, however, did not apply "to anyone" who engaged in the enumerated activities but, rather, only a subset of those who engaged in the covered behavior could be penalized under the ordinance. The Supreme Court conditionally granted in part the petition for writ of mandamus, holding that the word "anyone" in the ballot language threatened to mislead the voters. View "In re Durnin" on Justia Law

In this property dispute between neighboring landowners, the Supreme Court reversed the decision of the court of appeals reversing the judgment of the trial court finding that Plaintiffs held peaceful and adverse possession of the disputed property for the requisite time, holding that Plaintiffs' pleading alleged a claim of trespass to try title by adverse possession.In reversing, the court of appeals ruled that the pleadings did not support the judgment because Plaintiffs described their claim as a quiet title action rather than a trespass to try title action. The Supreme Court reversed, holding (1) Plaintiffs' pleadings supported the submission of adverse possession to the jury; and (2) in substance and effect, Plaintiffs sued for title to the disputed property, and in denominated their claim as an "action to quiet title," Plaintiffs did not nullify the substance of their adverse-possession actions. View "Brumley v. McDuff" on Justia Law