Justia Texas Supreme Court Opinion Summaries

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

The Supreme Court affirmed the judgment of the court of appeals affirming the Texas Comptroller's audit of Sunstate Equipment, a heavy construction equipment renal company, on the grounds that Sunstate was not entitled to subtract certain delivery and pick-up costs as cost of goods sold (COGS) under Tex. Tax Code 171.1012, holding that Sunstate was not entitled to the subtraction it claimed under either section 171.1012(k-1) nor section 171.1012(i).After the Comptroller assessed deficiencies, penalties and interest totaling $140,495 Sunstate brought suit for a refund. The district court ordered a full refund of the amount paid, including interest. The court of appeals reversed, concluding that Sunstate was not entitled to subtract costs under section 171.1012(k-1) and that section 171.1012(i) did not independently authorize the cost subtractions. The Supreme Court affirmed, holding that neither statutory provision authorized Sunstate to subtract its delivery and pick-up costs as COGS. View "Sunstate Equipment Co. v. Hegar" on Justia Law

In this case concerning the scope of the Expedited Declaratory Judgment Act (EDJA), the Supreme Court held that the EDJA gives the trial court jurisdiction to declare whether the execution of contracts entered into by the San Jacinto River Authority to sell water to cities and other customers was legal and valid but not whether the Authority complied with the contracts in setting specific rates.The Authority, which used the revenue from the contracts to pay off its bonds, sought declarations regarding the contract and the specific water rates set forth pursuant to the contracts. Several cities filed pleas to the jurisdiction, arguing that the trial court lacked subject matter jurisdiction to adjudicate SJRA's claims under the EDJA. The trial court denied the pleas to the jurisdiction. On appeal, the court of appeals held primarily for the Authority. The Supreme Court reversed in part, holding (1) the trial court may exercise jurisdiction over the Authority's execution of the contracts - which met the statutory definition of "public security authorization" - but may not exercise jurisdiction over whether the Authority complied with the contracts in setting the water rates; and (2) the Cities' governmental immunity did not bar this EDJA suit, which was brought in rem to adjudicate interests in property. View "City of Conroe, Texas v. San Jacinto River Authority" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the judgment of the trial court reversing the decision of the Commissioner of Education upholding the decision of the North East Independent School District board to end Respondent's continuing teaching contract, holding that the record supported the board's and Commissioner's decisions.At issue was whether state and federal laws requiring school districts to record grades and evaluate student progress provide standards of conduct for the teaching provision such that the teacher's failure to comply with district policies implementing those laws supports termination for "good cause." The Commissioner agreed that Respondent's conduct was "good cause per se" for termination. The trial court reversed. The court of appeals affirmed, concluding that "good cause per se" has no basis in Tex. Educ. Code 21.156(a)'s good cause definition. The Supreme Court revered, holding (1) Respondent preserved her complaint for judicial review; (2) the Commissioner erred in employing the "good cause per se" test, which has no basis in the Education Code's plain text; and (3) evidence of a failure to meet a district policy that implements state law supports a good cause determination. View "North East Independent School District v. Riou" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the trial court's judgment granting Defendant's plea to the jurisdiction and dismissing Plaintiff's suit, holding that the court of appeals erred in concluding that Plaintiff's allegations were sufficient to establish standing.At the time Plaintiff was injured in a car accident he had a personal injury protection (PIP) policy through Farmers Texas County Mutual Insurance Company (Defendant). Defendant paid Plaintiff's incurred medical expenses pursuant to the policy, but the amount Defendant paid was not the medical providers' list rate but, rather, the negotiated rate between Plaintiff's health care insurer and the medical providers. Plaintiff demanded an additional payment amounting to the difference between what Defendant paid Plaintiff and the PIP policy maximum. After Defendant refused, Plaintiff sued. Defendant filed a plea to the jurisdiction, arguing that Plaintiff lacked standing to sue under the PIP policy because Plaintiff alleged no actual or threatened injury. The trial court granted the plea and dismissed the suit. The court of appeals reversed, concluding that Plaintiff's allegations were sufficient to establish standing to sue under the PIP policy. The Supreme Court reversed, holding that the evidence supported Defendant's contention that Plaintiff had not suffered any actual or threatened injury. View "Farmers Texas County Mutual Insurance Co. v. Beasley" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the decision of the trial court denying R.R.S.'s motion to withdraw his plea of "true" to allegations that he sexually assaulted his younger brother when he was thirteen years old, holding that a child's legal inability to consent to sex does not render the child legally incapable of committing aggravated sexual assault.Based on R.R.S.'s admissions and plea, the trial court found him delinquent. Before the disposition hearing, R.R.S. unsuccessfully filed a motion to withdraw his plea and requested a new trial. The court of appeals reversed the denial of the motion, ruling that because R.R.S. was not adequately informed when he entered his plea about his potential defense that he could not have committed aggravated sexual assault because he could not legally "consent to sex" the trial court erred in denying the motion. The Supreme Court reversed the court of appeals' decision and reinstated the trial court's judgment, holding that the court of appeals erred in holding that R.R.S.'s lack of knowledge of his inability to consent to sex required the trial court to grant his motion to withdraw his plea and for a new trial. View "State v. R.R.S." on Justia Law

The Supreme Court reversed the judgment of the court of appeals upholding the trial court's grant of summary judgment without addressing its legal merit, holding that the trial court's recital in its final summary judgment order that it considered "the pleadings, evidence, and arguments of counsel" included a late-filed response and attached evidence.Plaintiff sued Defendant alleging that she had been sexually assaulted at work. Defendant moved for summary judgment, presenting traditional and no evidence grounds. The trial court granted the motion. On remand from the Supreme Court, the court of appeals affirmed, concluding that Plaintiff failed to file a timely response to the no-evidence motion and that the trial court did not consider the late-filed response. The court of appeals declined to consider the evidence that Defendant had attached to its combined motion because no timely response pointed out a fact issue raised by that evidence. The Supreme Court reversed, holding (1) the trial court's recital that it considered the "evidence and arguments of counsel," without limitation, was an "affirmative indication" that the trial court considered Plaintiff's response and the evidence attached to it; and (2) therefore, the court of appeals should have considered that evidence as well in its review of the trial court's summary judgment. View "B.C. v. Stake N Shake Operations, Inc." on Justia Law