Justia Texas Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals holding that the Texas Farm Animal Activity Act (the Act), Tex. Civ. Proc. & Rem. Code 87.001-87.005, does not apply to ranchers and ranch hands, holding that the court of appeals did not err.The Act limits liability for injury to "a participant in a farm animal activity or livestock show" that results from an "inherent risk" of those activities. Raul Zuniga worked full-time for Conway and Marlene Waak to work cattle on a ranch, landscape, and cut hay. Zuniga died after being trampled. Plaintiffs, Zuniga's family, sued the Waaks, on wrongful death and survival claims. The trial court granted summary judgment for the Waaks, concluding that the Act barred Plaintiffs' claims. The court of appeals reversed, concluding that Zuniga was not "a participant in a farm animal activity" for whose injuries and death the Act limits liability. The Supreme Court affirmed, holding that the Act does not cover ranchers and ranch hands and, therefore, did not shield the Waaks from liability for their negligence resulting in Zuniga's death. View "Waak v. Rodriguez" on Justia Law

The Supreme Court reversed the decision of the court of appeals holding that a forum-selection clause in a contract bound all involved parties even where the only signatories did not assert any claims against one another, holding that the court of appeals erred in construing the contract containing the forum-selection clause and a contract that did not as a single, unified instrument and by applying the transaction-participant enforcement theory.Personal jurisdiction over two nonresident individuals and a nonresident LLC was premised on a forum-selection clause in a contract the nonresident LLC executed with a resident LLC. A signatory LLC sought to enforce the clause against nonsignatory individuals, and nonsignatory individuals sought to enforce the clause against nonsignatory individuals and a signatory LLC. The court of appeals concluded that all defendants were amenable to suit in Texas regardless of their status as a signatory. The Supreme Court reversed, holding (1) the separately executed instruments considered by the court of appeals were not part of a single, unified instrument and, therefore, must be construed separately; and (2) the transaction participant enforcement theory relied upon by the court of appeals was inapplicable. View "Rieder v. Woods" on Justia Law

The Supreme Court reversed the judgment of the court of appeals on Plaintiff's survival action and rendered judgment for Defendant, holding that Plaintiff's claims were barred by the exclusive-remedy provision of the Texas Workers' Compensation Act because her evidence did not raise a fact issue under the intentional-injury exception to the Act's exclusive remedy.Plaintiff's husband, an employee of Defendant, a trucking and warehousing company, died when his rig ran off the highway and rolled over. Plaintiff filed suit, arguing that her husband fell asleep at the wheel due to the fatigue of being overworked. At issue was whether there was any evidence that Defendant believed the accident was substantially certain to result from Plaintiff's being overworked. The trial court granted summary judgment for Defendant. The court of appeals reversed. The Supreme Court reversed, holding that Plaintiff failed to raise a fact issue on the applicability of the intentional-injury exception to the exclusive-remedy provision of the Act. View "Mo-Vac Service Co., Inc." on Justia Law

The Supreme Court concluded that, as to Plaintiffs' fraud claims, GTECH Corporation, a private contractor, would not qualify for derivative sovereign immunity for services it provided to the Texas Lottery Commission even if the Court recognized that doctrine but that GTECH was entitled to immunity from Plaintiffs' allegations of aiding and abetting the Commission's fraud and of conspiracy with the Commission.The Commission contracted with GTECH for instant ticket manufacturing and services. Plaintiffs filed two separate suits alleging that the instructions on a scratch-off lottery ticket mistakenly caused them to believe they had winning tickets. GTECH filed pleas to the jurisdiction, arguing that it was entitled to the Commission's immunity. The Dallas County trial court granted GTECH's plea to the jurisdiction. The Travis County trial court denied the plea. The Dallas Court of Appeals affirmed. The Austin Court of Appeals affirmed in part and reversed in part. The Supreme Court held (1) GTECH was not entitled to immunity from Plaintiffs' fraud claims because the Commission did not control GTECH's choices in writing the game instructions; and (2) GTECH was entitled to immunity from the theories of conspiracy and of aiding and abetting because Plaintiffs must necessarily override the substance of the Commission's underlying decisions in order to impose derivative liability on GTECH. View "GTECH Corp. v. Steele" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the trial court concluding that a state agency violated the Texas Whistleblower Act, Tex. Gov't Code 554.002, when it fired one of its employees, holding that, under City of Fort Worth v. Zimlich, 29 S.W.3d 62 (Tex. 2000), no evidence demonstrated that the employee's report of a violation of state law more than one year earlier caused the agency to terminate the employee's employment.Laura Rodriguez, a regional manager for child-support services with the Office of the Attorney General, was fired fifteen months after reporting a violation of state law. Rodriguez sued the agency, claiming that it violated the Act because it fired her in retaliation for her protected activity. The trial court concluded that Rodriguez had made a good-faith report of a violation of law that caused the agency to terminate her employment. The court of appeals affirmed. The Supreme Court reversed, holding that the record evidence demonstrated that Rodriguez was fired based on conduct unrelated to her protected activity and that no evidence established that activity was a but-for cause of her termination. View "Office of Attorney General of Texas v. Rodriguez" on Justia Law

In this labor dispute, the Supreme Court affirmed the judgment of the court of appeals reversing the order of the trial court granting Defendant's motion for judgment notwithstanding the verdict (JNOV), holding that Defendant did not carry its burden to establish that Plaintiff was its borrowed employee.Plaintiff sued Defendant for negligence after he was injured while working on an offshore drilling rig owned by Defendant. Although Plaintiff was not Defendant's employee, Defendant claimed that workers' compensation benefits were Plaintiff's sole remedy because Plaintiff was acting as its "borrowed employee" under the federal Longshore and Harbor Workers' Compensation Act (LHWCA). The jury found that Plaintiff was not Defendant's borrowed employee and awarded damages to Plaintiff. The trial court granted Defendant's JNOV motion, finding that the submission of the borrowed-employee question to the jury was improper and that the evidence supported Defendant's borrowed-employee defense. The court of appeals reversed, holding that the borrowed-employee inquiry can be a fact question for the jury. The Supreme Court affirmed, holding (1) the trial court correctly determined that the borrowed-employee inquiry was a legal question for the court, not a fact question for the jury; but (2) Defendant did not establish that Plaintiff was its borrowed employee. View "W&T Offshore, Inc. v. Fredieu" on Justia Law

The Supreme Court held that a lack of immunity to COVID-19, without more, is not a "disability" that renders a voter eligible to vote by mail within the meaning of Tex. Elec. Code Ann. 82.002(a) and declined to issue a writ of mandamus sought by the State prohibiting Respondents, election officials, from improperly approving applications for mail-in ballots for the July and November 2020 elections, stating that the Court was confident that Respondents will comply.Under the Texas Election Code, qualified voters are eligible to vote by mail in only five specific circumstances, including if the voter has a "disability." At issue in this case was whether a voter's lack of immunity from COVID-19 and concern about contracting it at a polling place is a "disability" within the meaning of section 82.002. The Supreme Court held that a voter's lack of immunity to COVID-19 is not a "disability" as defined by the Election Code. Because Respondents assured the Court that they will fully discharge their duty to follow the law the Supreme Court concluded that issuing the writ of mandamus to compel them to do so was unwarranted. View "In re State of Texas" on Justia Law

The Supreme Court held that open-enrollment charter schools and their charter-holders have governmental immunity from suit and liability to the same extent as public schools and that, in this case, the open-enrollment charter school district had immunity from suit.The Burnham Wood Charter School District, which operates open-enrollment charter schools in El Paso, repudiated a lease with Amex Properties, LLC to lease certain property. Amex sued the district for anticipatory breach of the lease. The district filed a plea to the jurisdiction contending that it was immune from suit to the same extent as public school districts and that no waiver of immunity existed for Amex's claim. The trial court denied the district's jurisdictional plea, and the court of appeals affirmed. The Supreme Court reversed and dismissed the suit for want of jurisdiction, holding (1) open-enrollment charter schools have governmental immunity to the same extent as public schools; (2) Tex. Local Gov't Code 271 waives governmental immunity for breach of contract claims brought under the chapter; and (3) the lease in this case was not properly executed under section 271.151, and therefore, Amex's breach of contract claim was not waived under section 271.152. View "El Paso Education Initiative, Inc. v. Amex Properties, LLC" on Justia Law

In this dispute over which faction of a splintered Episcopal diocese is the "Episcopal Diocese of Fort Worth" the Supreme Court affirmed the trial court's grant of summary judgment in favor of the withdrawing faction, holding that resolution this property dispute does not require consideration of an ecclesiastical question and that, under the diocese's governing documents, the withdrawing faction is the Episcopal Diocese of Fort Worth.After a disagreement about religious doctrine the Episcopal Diocese of Fort Worth and a majority of its congregations withdrew from The Episcopal Church. The church replaced the diocese's leaders. Subsequently, both the disaffiliating and replacement factions claimed ownership of property held in trust for the diocese and local congregations. The withdrawing faction argued that under the organizational documents, the unincorporated association's identity is determined by the majority. The church and its loyalists argued that the entity's identity is an ecclesiastic determination. The Supreme Court agreed with the withdrawing faction by applying neutral principles to the disputed facts, holding that the trial court property granted summary judgment in the withdrawing faction's favor. View "Episcopal Diocese of Fort Worth v. Episcopal Church" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals holding that the University of the Incarnate Word does not have sovereign immunity when it is sued in connection with its law-enforcement activities, holding that neither the doctrine's purposes nor the operative legislation supports extending sovereign immunity to the University as a private entity.A deceased student's parents sued a University peace officer and the University after the officer shot the student following a traffic stop. The Supreme Court previously held that the University may appeal from an adverse ruling on its jurisdictional plea of governmental immunity but remanded to the court of appeals to consider whether the State's sovereign immunity extends to the University. The court of appeals declined to hold that the University possesses sovereign immunity. The Supreme Court affirmed, holding (1) private universities do not operate as an arm of the State government through their police departments; and (2) extending sovereign immunity to the University does not comport with the doctrine's purposes, nor is it consistent with enabling legislation that extends immunity to peace officers engaged in law enforcement activities. View "University of the Incarnate Word v. Redus" on Justia Law