Justia Texas Supreme Court Opinion Summaries

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

The Supreme Court reversed the judgment of the court of appeals concluding that an insurer's payment of an appraisal award bars an insured's claim under the Texas Prompt Payment of Claims Act (TPPCA), Tex. Ins. Code 542.051-.061, holding that the court of appeals' opinion was inconsistent with this Court's recent decisions on this issue.Insurer issued Insured payment under Insured's insurance policy after Insured's residential property sustained wind and hail damage. Insured later sued, believing that the property damages were undervalued. The trial court compelled appraisal, and the appraisal awarded exceeded Insurer's prior estimates. Insurer paid the award to Insured. The trial court subsequently granted summary judgment on all of Insured's claims. The court of appeals affirmed, concluding that payment of an appraisal award entitles an insurer to summary judgment on all of the insured's claims. The Supreme Court reversed, holding that the court of appeals' conclusion was in error 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 "Alvarez v. State Farm Lloyds" on Justia Law

The Supreme Court reversed the judgment of the court of appeals concluding that an insurer's payment of an appraisal award bars an insured's claim under the Texas Prompt Payment of Claims Act (TPPCA), Tex. Ins. Code 542.051-.061, holding that the court of appeals' opinion was inconsistent with this Court's recent decisions on this issue.Insurer issued Insured payment under Insured's insurance policy after Insured's residential property sustained wind and hail damage. Insured later sued, believing that the property damages were undervalued. The trial court compelled appraisal, and the appraisal awarded exceeded Insurer's prior estimates. Insurer paid the award to Insured. The trial court subsequently granted summary judgment on all of Insured's claims. The court of appeals affirmed, concluding that payment of an appraisal award entitles an insurer to summary judgment on all of the insured's claims. The Supreme Court reversed, holding that the court of appeals' conclusion was in error 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 "Lazos v. State Farm Lloyds" on Justia Law

In this dispute over the amount of franchise tax owed by a taxpayer the Supreme Court reversed in part the judgment of the court of appeals reversing in part the trial court's judgment for the taxpayer, holding that, with respect to the taxpayer's inclusion of certain costs in its "cost of goods sold" (COGS) subtraction, the calculation method accepted by the trial court was improper, and the taxpayer was not entitled to include the costs in calculating its COGS subtraction.The Comptroller concluded that Gulf Copper and Manufacturing Corporation paid an insufficient amount of franchise taxes for the 2009 year. At issue was whether Gulf Copper could exclude certain payments from its revenue under Texas Tax Code 171.1011(g)(3) and include certain costs in its COGS subtraction under Texas Tax Code 171.1012. Gulf Copper paid additional taxes and sued to recover the disputed amount. The trial court rendered judgment in favor of Gulf Copper. The court of appeals reversed in part. The Supreme Court reversed in part, holding (1) the Comptroller incorrectly disallowed the revenue exclusion; (2) with regard to the COGS subtraction, the calculation method accepted by the trial court was improper; and (3) the taxpayer was not entitled to include costs under subsection 171.1012(i) in calculating its COGS subtraction. View "Hegar v. Gulf Copper & Manufacturing Corp." on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the trial court concluding that Tex. Tax Code 171.1012 permitted a movie theater to subtract exhibition costs as cost of goods sold, holding that film exhibitions are not tangible personal property that is sold, and therefore, the theater was not entitled to include exhibition-related costs in its cost of goods sold.The Comptroller disallowed the movie theater's subtraction of exhibition costs in calculating its franchise tax liability for 2008 and 2009. The theater paid the additional franchise taxes requested by the Comptroller and sued to recover the disputed amount, arguing that its exhibition costs were property subtracted as cost of goods sold (COGS). The trial court concluded that the theater's film exhibitions were tangible personal property and thus goods for sale in the ordinary course of the theater's business under section 171.1012. The court of appeals affirmed. The Supreme Court reversed, holding that section 171.1012 did not permit the movie theater to subtract is exhibition costs as COGS because no tangible personal property was transferred through the film exhibitions. View "Hegar v. American Multi-Cinema, Inc." on Justia Law