Justia Texas Supreme Court Opinion Summaries

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

In this insurance dispute, the Supreme Court answered a question of Texas law in a case certified from the United States Court of Appeals for the Fifth Circuit by stating that a "policy-language exception" to the "eight-corners rule" is not a permissible exception under Texas law.The certified question asked about the "eight-corners rule," which is given its name by the "four corners" of the petition and the "four corners" of the policy. Under the eight-corners rule an insurer's "duty to defend is determined by the claims alleged in the petition and the coverage provided in the policy. The instant case concerned a dispute as to whether State Farm must defend its insureds against personal injury claims. According to one federal district court applying Texas law, the eight-corners rule does not apply unless the policy includes language requiring the insurer to defend all actions against its insured, even if the allegations are groundless, fraudulent, or false. The case made its way to the federal district court, which asked whether the "policy-language exception" to the eight-corners rule was a permissible exception under Texas law. The Supreme Court answered that it was not. View "Richards v. State" on Justia Law

In this workers' compensation case involving the death of a deputy sheriff who died in a vehicular accident while driving his assigned patrol car the Supreme Court reversed the judgment of the court of appeals reversing the summary judgment rendered by the trial court for the deputy's widow, holding that, at the time of the accident, the deputy was engaged in law enforcement activity within the course and scope of his employment.In granting summary judgment fort he deputy's widow the trial court concluded that the deputy was in the course and scope of his duties at the time of his death. The court of appeals reversed, concluding that because the accident occurred during the deputy's travel home from an extra-duty assignment with a private employer the deputy was not in the course and scope of his employment. The Supreme Court reversed, holding (1) the deputy was operating the marked patrol car with the county's permission and under its authority at the time of his death; and (2) therefore, summary judgment was properly granted in the widow's favor. View "Orozco v. County of El Paso" on Justia Law

In this termination of parental rights case the Supreme Court granted Father's petition and affirmed in part and reversed in part the judgment of the court of appeals affirming the trial court's termination of Father's parental rights, holding that there was no error that warranted reversal as to the termination of Father's parental rights but that the court of appeals erred by not detailing its analysis as required by In re N.G., 577 S.W.3d 230 (Tex. 2019).The trial court found clear and convincing evidence of ground to terminate Father's parental rights under Tex. Family Code 161.001(b)(1)(D),(E),(F),(N), and (O). The court further found that termination was in the child's best interest. The court of appeals affirmed. Father appealed, arguing, among other things, that the court of appeals erred by failing to detail its analysis of the trial court's findings as to grounds (D) and (E) in violation of In re N.G. The Supreme Court reversed in part, holding that the court of appeals properly found that termination was warranted in this case but erred in not detailing its analysis of whether legally and factually sufficient evidence supported termination of parental rights under section 161.001(b)(1)(D) and (E). View "In re Interest of L.G." on Justia Law

The Supreme Court conditionally granted Mobile Mini, Inc.'s petition for writ of mandamus and directed the trial court to vacate its order denying Mobile Mini's motion to designate a responsible third party in a construction worker's personal injury suit, holding that the trial court was obligated to grant Mobile Mini's motion to designate a responsible third party under the circumstances of this case.Mobile Mini, the owner of a construction trailer, was sued for injuries Luis Covarrubias received when a wind gust blew the door of the trailer closed on his hand. Mobile Mini filed a motion to designate Nolana Self Storage, LLC, the owner of the construction site, as a responsible third party so a jury could determine whether Nolana caused or contributed to Covarrubias's injury. The trial court denied Mobile Mini's request. The court of appeals denied Mobile Mini's mandamus petition. The Supreme Court conditionally granted the petition and directed the trial court to vacate its order denying Mobile Mini's motion to designate Nolana as a responsible third party, holding that Mobile Mini's discovery response disclosing Nolana as a potentially responsible third party was timely even though it was served after the statute of limitations had expired on Covarrubias's tort claims. View "In re Mobile Mini, Inc." on Justia Law

In this premises-liability case arising out of a brown recluse spider bite the Supreme Court reversed the judgment of the court of appeals ruling that the property owner failed conclusively to establish the absence of a duty and thus reversing the trial court's summary judgment in his favor, holding that the landowner owed no duty to his bitten invitee.Defendant leased a cabin to Plaintiff on property in Fredericksburg, Texas. Plaintiff accessed a neighboring home, also owned by Defendant, at Defendant's request and, while there, was bitten by a brown recluse spider. Plaintiff sued for negligence under a premises-liability theory. Defendant filed a motion for summary judgment, arguing that under the doctrine of ferae naturae, he owed no duty to Plaintiff with respect to indigenous wild animals that Defendant had neither introduced to nor harbored on the property. The trial court granted summary judgment for Defendant. The court of appeals reversed. The Supreme Court reversed, holding that Defendant owed Plaintiff no duty as a matter of law under the circumstances of this case. View "Hillis v. McCall" on Justia Law

The Supreme Court reversed in part the judgment of the court of appeals affirming the trial court's judgment concluding that several general easements that Petitioner, an electric company, acquired in 1949 from the predecessors-in-title to Respondents, landowners, were fixed at a thirty-foot width and rendering judgment for Respondents, holding that the plain language of the easements did not include a fixed width for the easements, nor were the easements required to do so.Petitioner argued in this case that the easements were general easements with no fixed width. Respondents, in turn, argued that the easements should have a fixed, thirty-foot width. The trial court rendered judgment for Respondents. The court of appeals affirmed, concluding that because the original easements did not specify a width, the trial court properly admitted extrinsic evidence of past use to determine how much of Respondents' land was reasonably necessary for Petitioner to utilize pursuant to the easements. The Supreme Court reversed, holding that Respondents' properties were burdened by general easements with no defined width and that the lack of a specified width in an easement does not mandate the admission of extrinsic evidence to prescribe a width. View "Southwestern Electric Power Co. v. Lynch" on Justia Law