Justia Texas Supreme Court Opinion Summaries

The Supreme Court reversed the decision of the court of appeals reversing the trial court's judgment and commitment order and reinstated the judgment of the trial court ordering Gregory Jones civilly committed as a sexually violent predator (SVP) under Tex. Health and Safety Code chapter 841, holding that the trial court erred when it declined to submit an instruction explaining that a verdict for Jones required only ten votes out of a jury of twelve, but the error was harmless.A civil-commitment trial conducted under chapter 841 provides that a verdict may be rendered by the agreement of ten members of a twelve-person jury. By statute, however, a civil-commitment verdict finding that the defendant is a sexually violent predator must be unanimous. On appeal, Jones argued that the trial court erred when it declined to submit his instruction that a final verdict for the defendant required only ten out of twelve votes. The court of appeals agreed, held that the error was harmful, and reversed. The Supreme Court reversed, holding that the trial court's failure to submit the requested 10-2 instruction did not probably cause the rendition of an improper judgment, and therefore, the trial court's legal error was harmless. View "In re Commitment of Gregory Jones" on Justia Law

In this products-liability and wrongful-death suit, the Supreme Court vacated the order of the trial court sanctioning an attorney for commissioning a pretrial survey that commenced in the county of suit shortly before trial, holding that the sanctions order, issued under the court's inherent authority, could not stand because evidence of bad faith was lacking.After a hearing, the trial court imposed sanctions against the attorney that commissioned the pretrial survey, ordering the attorney to complete ten hours of legal ethics education and pay the movants $133,415 in attorneys fees and expenses. The court did not find that the attorney violated any disciplinary rules or other applicable authority, instead concluding that the attorney's conduct was intentional, in bad faith, and an abuse of the legal system and the judicial process. The court of appeals affirmed. The Supreme Court reversed, holding (1) the attorney's attitude and intermittent obstinance at the sanctions hearing likely taxed the trial court's patience but did not itself justify the imposition of sanctions; and (2) the attorney's errors in commissioning and executing the survey did not constitute bad faith. View "Brewer v. Lennox Hearth Products, LLC" on Justia Law

In this case arising from an inflated appraisal of certain property and governed by New York law, the Supreme Court reversed in part the court of appeals' decision affirming the jtrial court's judgment awarding Claymore Holdings $211 million in equitable relief, holding that there was no valid basis in New York law for this large award of equitable monetary relief.The subject property was a real estate project. Claymore loaned the project $250 million and took the real estate as collateral. After the borrower defaulted and the collateral's value declined, Claymore sued Credit Suisse, which helped arrange the transaction, alleging that Credit Suisse fraudulently inflated the appraisal of the real estate, inducing Claymore to make the loan, and that the faulty appraisal amounted to a breach of contract. A jury found for Claymore on the fraudulent inducement claim and awarded $40 million. The court found Credit Suisse liable for breach of contract and other theories but concluded that Claymore's damages on all claims could not be calculated with reasonable certainty. The court then awarded Claymore $211 million in equitable relief. The Supreme Court remanded the case, holding that the jury's $40 million fraud verdict must stand but that the court's award of $211 million in equitable relief must not. View "Credit Suisse AG v. Claymore Holdings, LLC" on Justia Law

In this title dispute between the State and a private landowner over portions of the submerged bed of Lone Oak Bayou the Supreme Court reversed the trial court's summary judgment in favor of the landowner, holding that there were factual disputes to be resolved, precluding summary judgment.Lone Oak Bayou was a navigable body of water located near the Gulf of Mexico. The landowner's predecessor bought land from the State that included the Bayou's bed. Later, the Legislature passed a statute (the Small Bill) validating conveyances that included the beds of "watercourses or navigable streams." The Commissioner of the General Land Office argued that the Small Bill did not validate the landowner's title to the Bayou's bed because the tide enters the Bayou and the statute conveyed only submerged beds underlying non-tidally influenced streams. The trial court granted summary judgment for the Landowner. The court of appeals affirmed. The Supreme Court reversed, holding that there were factual disputes to be resolved regarding whether the Bayou is a navigable stream within the scope of the statutory conveyance. View "Bush v. Lone Oak Club, LLC" on Justia Law

The Supreme Court conditionally granted mandamus relief to the State seeking review of a temporary restraining order (TRO) blocking enforcement of Executive Order GA-13, which changes the rules applicable to judges' decisions regarding pre-trial bail, against judges, holding that the trial court lacked jurisdiction to order the judges' requested relief, even temporarily.GA-13 suspends certain statutes authorizing trial judges to release jail inmates with violent histories during the state of disaster due to the threat of the novel coronavirus. Plaintiffs alleged that GA-13 is unconstitutional and exceeds the governor's statutory emergency powers. Sixteen of the plaintiffs were Texas trial judges alleging that GA-13 improperly interferes with their judicial authority to make individualized bail decisions, and the other plaintiffs were public interest organizations and lawyer associations. The trial court issued a TRO blocking enforcement of GA-13 against judges. The Supreme Court conditionally granted mandamus relief, holding that the alleged threat of a criminal prosecution in this case did not give the judges standing to seek the invalidation of GA-13, and therefore, the trial court lacked jurisdiction to order their requested relief. View "In re Greg Abbott" on Justia Law

The Supreme Court reversed the judgment of the court of appeals dismissing Appellant's appeal of the trial court's grant of summary judgment for Plaintiff and against Defendants for want of jurisdiction, holding that, contrary to the decision of the court of appeals, the trial court's judgment was final and appealable.Plaintiff sued Defendants for declaratory judgment and monetary damages arising from a commercial construction project. The trial court awarded summary judgment in favor of Plaintiff. Despite the trial court's confirmation of its intent to render a final judgment, the court of appeals concluded that no final judgment had been rendered. The Supreme Court reversed, holding that the court of appeals erred by analyzing the record for evidence of finality after the trial court provided a clear and unequivocal statement that it had intended the appealed-from order to be a final judgment. View "Bella Palma, LLC v. Young" on Justia Law

In this interlocutory appeal involving application of the Texas Tort Claims Act's (TTCA) notice requirement the Supreme Court reversed the decision of the court of appeals reversing the judgment of the trial court denying Jefferson County's jurisdictional plea, holding that the County had actual notice of the plaintiff's claim as a matter of law.Plaintiff sued Jefferson County under the Texas Tort Claims Act, Tex. Civ. Proc. & Rem. Code 101.101. The County asserted noncompliance with section 101.101, but the County's plea to the jurisdiction sought dismissal only on non-TTCA grounds, including noncompliance with a presentment requirement in Tex. Local Gov't Code 89.004(a). The trial court denied the County's plea on the basis that section 89.004's presentment requirement was not jurisdictional. The court of appeals reversed and dismissed the suit with prejudice for lack of statutory notice without considering the merits of the section 89.004 presentment issue. The Supreme Court reversed, holding that the court of appeals erred in ruling that Plaintiff failed to provide the notice section 101.101 requires to invoke the TTCA's sovereign immunity waiver. View "Reyes v. Jefferson County" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the judgment of the trial court granting the City of Madisonville's jurisdictional plea claiming that David Sims' Texas Whistleblower Act claim was time-barred because it was filed after the Act's ninety-day filing deadline, holding that, contrary to the ruling of the court of appeals, the filing deadline was jurisdictional.In reversing the trial court, the court of appeals held that the Act's ninety-day filing deadline was not jurisdictional because a statute of limitations may be raised as an affirmative defense at the summary-judgment stage but not as the basis for a jurisdictional plea. The Supreme Court reversed and dismissed the case for lack of jurisdiction, holding that because the claim here was against a governmental entity the filing deadline was jurisdictional. View "City of Madisonville v. Sims" on Justia Law

In this insurance dispute over whether an insurer's payment of an appraisal award obtained under a unilateral appraisal clause bars an insured's claims under the Texas Prompt Payment of Claims Act (TPPCA), Tex. Ins. Code chapter 542 the Supreme Court reversed the judgment of the court of appeals concluding that Insured's claims were barred, holding that Insured's claims should be considered in light of this Court's recent decisions on these issues.After Insurer declined to pay for damage to Insured's properties Insured asked to invoke the policy's appraisal process. Insurer refused, asserting that it was the only party that could invoke appraisal under the unilateral appraisal clause. Insured sued Insurer alleging claims for breach of contract, bad faith, and violations of the TPPCA. Insurer then obtained an order compelling appraisal. After Insurer paid the appraisal award the trial court granted summary judgment for Insurer. The court of appeals affirmed. The Supreme Court reversed, holding that remand was required for the trial court to consider Insured's claims in light of Barbara Technologies Corp. v. State Farm Lloyds, 589 S.W.3d 806 (Tex. 2019), and Ortiz v. State Farm Lloyds, 589 S.W.3d 127 (Tex. 2019). View "Biasatti v. GuideOne National Insurance Co." on Justia Law

In this complaint alleging ultra vires claims against Mike Morath, in his official capacity as the Commissioner of the Texas Education Agency, the Supreme Court granted Respondents' motion to dismiss this appeal as moot, dismissed the case as moot, and vacated both the judgment and opinion of the court of appeals without respect to the merits, holding that the case must be dismissed as moot.Morath filed a plea to the jurisdiction, alleging that Respondents' claims could not proceed for several reasons. The trial court denied the plea to the jurisdiction, and the court of appeals affirmed. Morath petitioned for review. After Morath filed his merits brief, Respondents decided to stop pursuing their claims and filed a "notice of nonsuit without prejudice." Respondents then moved to dismiss the appeal as moot. Morath opposed the motion to dismiss, arguing that a non-suit was ineffective and, alternatively, that this appeal involved a matter of public concern. The Supreme Court dismissed the appeal, holding that that this case is now moot, and in the absence of jurisdiction this case must be dismissed. View "Morath v. Lewis" on Justia Law