Justia Texas Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals reversing the trial court's judgment in this dispute over a particular provision in a land-improvement contract, holding that the court of appeals erred in concluding that the contract was ambiguous and could not be established as a matter of law.The trial court interpreted the disputed provision as a matter of law and instructed the jury accordingly. The court then entered judgment based on the jury's verdict, which resolved the issues of liability and damages. The court of appeals reached the same result as the trial court but nevertheless reversed, determining that, despite its analysis of the language of the contract, the provision was still ambiguous. The court then ordered a new trial so that a jury could determine the meaning of the contractual text. The Supreme Court reversed and remanded the case for further proceedings, holding that the trial court correctly construed the subject provision, and the court of appeals erred in ruling that the provision was ambiguous. View "U.S. Polyco, Inc. Texas Central Business Lines Corp." on Justia Law

In this case involving mandates requiring people to wear face masks or other coverings to prevent the spread of COVID-19 the Supreme Court vacated the judgment and opinion of the court of appeals and dismissed this interlocutory appeal, holding that the appeal was moot.In 2021, the City of El Paso obtained a temporary injunction against the enforcement of GA-38, a gubernatorial executive order that prohibited local mask-wearing requirements. The court of appeals affirmed. In 2023, Senate Bill 29, codified as Tex. Health & Safety Code 81.B.001-.004, which provided that a governmental entity may not impose mask-wearing requirement to prevent the spread of COVID-19, went into effect. Further, GA-38 expired. The Supreme Court vacated the court of appeals and dismissed this appeal, holding that no live controversy remained between the parties. View "Abbott v. City of El Paso" on Justia Law

The Supreme Court dismissed this interlocutory appeal as moot and vacated the judgment of the court of appeals in this case arising from the Covid-19 pandemic, holding that the public interest was best served by vacatur of the court of appeals' opinion and that the State was prevented from challenging on the merits due to mootness.When the San Antonio Independent School District (ISD) required that its employees take a Covid-19 vaccine by October 15 2021, the State sued, seeking a temporary injunction arguing that the vaccine requirement violated a gubernatorial executive order. The district court denied relief. The court of appeals affirmed. The Supreme Court denied the ensuing appeal as moot, holding that neither the enforceability of the ISD's vaccine mandate, which was barred by Senate Bill 29, nor the enforceability of executive order GA-39, which had expired, left a live controversy between the parties. View "State v. San Antonio Independent School District" on Justia Law

The Supreme Court reversed the judgment of the court of appeals dismissing Father's appeal of the termination of his parental rights, holding that Father properly invoked the court's jurisdiction, and therefore the court erred in dismissing Father's appeal on jurisdictional grounds.After a joint bench trial and in a single order the trial court ordered termination of both Father's and Mother's rights. Father noticed his appeal to one of two courts of appeals with jurisdiction to entertain his appeal, and Mother noticed her appeal to the other court. Although Father amended his notice to consolidate his appeal into the court of appeals in which Mother's appeal was pending, the court of appeals determined that the amended notice did not vest it with jurisdiction. The Supreme Court reversed and remanded the case, holding that the merits were properly before the court of appeals at issue, and therefore, the court erred in dismissing Father's appeal for want of jurisdiction. View "In re A.B." on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the judgment of the trial court that two expert reports provided to support Plaintiff's claims for negligence provided the information required by the Texas Medical Liability Act, Tex. Civ. Proc. & Rem. Code 74.351(a), (l), (r)(6), holding that the trial court did not abuse its discretion in denying Defendant's motion to dismiss.Plaintiff, the guardian of a care facility resident, sued Defendant, the facility, alleging negligence. The trial court concluded that the two expert reports provided by Plaintiff to support the claims provided a fair summary of the experts' opinion regarding the standard of care, breach, and the cause of injury, as required by the Act. The court of appeals reversed on the ground that the reports lacked sufficient detail regarding the appropriate standard of care and breach. The Supreme Court reversed, holding that the proffered reports provided a fair summary of the experts' opinions as to the appropriate standard of care and breach of that standard. View "Uriegas v. Kenmar Residential HCS Services, Inc." on Justia Law

The Supreme Court reversed the judgment of the court of appeals concluding that the State must prove that the victim did not consent in order to show that a child under the age of fourteen had the requisite intent to commit aggravated sexual assault of another child under fourteen, holding that the statutory text of Tex. Penal Code 22.021(a)(1)(B), (2)(B) foreclosed the court's result.At the time of the offense in this case, the accused was thirteen years old and the complainant was twelve. At issue was whether the victim's consent may inform the determination of the accused individual's mens rea when both the accused the the complainant are under fourteen and close in age. The court of appeals reversed the trial court's adjudication order and dismissed the case with prejudice. The Supreme Court reversed and remanded the case for further proceedings, holding that, under the totality of the circumstances of this case, the victim's consent could not inform the determination of the accused's mens rea under section 22.021(a)(1)(B), (2)(B). View "In re T.V.T." on Justia Law

The Supreme Court reversed the judgment of the court of appeals in the underlying insurance dispute, holding that the insurance policy at issue did not incorporate the payout limits in an underlying service agreement.ExxonMobil Corporation hired Savage Refinery Services to work as an independent contractor at Exxon's Baytown refinery, and the parties memorialized their arrangement with a service agreement. Under the agreement, Savage promised to obtain at least a minimum stated amount of liability insurance for its employees and to name Exxon as an additional insured. Savage ultimately procured five different insurance policies, three of which were underwritten by National Union Fire Insurance Company and Starr Indemnity & Liability Insurance Company. After a workplace accident at the Baytown Refinery two injured employees sought compensation. Plaintiffs settled with Exxon for $24 million. When National Union and Starr denied Exxon coverage under their umbrella policies Exxon sued for breach of contract. The trial court ruled for Exxon. The court of appeals reversed, concluding that Exxon was not insured under National Union's umbrella policy. The Supreme Court reversed, holding that Exxon was an "insured" under National Union's umbrella policy and that the lower court's ruling with respect to Starr's bumbershoot policy was predicated on a similar error. View "ExxonMobil Corp. v. Nat'l Union Fire Insurance Co. of Pittsburgh, PA" on Justia Law

The Supreme Court reversed the trial court's denial of Defendant's motion to compel arbitration, holding that remand was required for reconsideration in light of this Court's holdings in TotalEnergies E&P USA, Inc. v. MP Gulf of Mexico, LLC, 667 S.W.3d 694 (Tex. 2023).Lone Star Cleburne Autoplex filed this suit asserting that Alliance Auto Auctions of Dallas conspired with two of Lone Star's employees in order to embezzle money from Lone Star. Alliance moved to compel arbitration based on arbitration clauses contained in authorization agreements between Lone Star and a company Alliance used to verify and authorize car dealerships to buy and sell in the company's auctions. In opposing the motion Lone Star asserted that its claims fell outside the scope of the arbitration agreement. The trial court denied Alliance's motion to compel. The court of appeals affirmed. The Supreme Court reversed, holding that because the court of appeals decided this case without addressing arguments rejected in TotalEnergies, remand was required. View "Alliance Auto Auction of Dallas, Inc. v. Lone Star Cleburne Autoplex, Inc." on Justia Law

The Supreme Court reversed the judgment of the court of appeals in this personal injury case, holding that the court of appeals erred in concluding that the trial court abused its discretion in admitting Valerie McElwrath's lay testimony and in determining that the admission of her testimony probably caused the rendition of an improper judgment.Reuben Hitchcock fell to the ground while he was standing in the front-end loader of a tractor and was trimming the tree of his neighbor, Defendant. Later that night, Hitchcock called for an ambulance and was hospitalized. He died one month later. Plaintiff, Hitchcock's sister, brought this action alleging that Defendant was negligent and grossly negligent for failing to take certain actions. The jury rendered a verdict for Defendant, and the trial court rendered a take-nothing judgment on the jury's verdict. The court of appeals reversed, holding that the trial court's error in admitting the testimony of McElwrath, Hitchcock's neighbor, was prejudicial. The Supreme Court reversed, holding that the admission of McElwrath's testimony, even if erroneous, did not constitute harmful, reversible error. View "Jackson v. Takara" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the order of the trial court dismissing Duncan House Charitable Corporation's application for a charitable organization exemption, holding that the court of appeals erred in concluding that Duncan's failure to timely apply for later exemption precluded it from receiving that exemption even if it ultimately qualified for an earlier exemption.For the 2017 tax year, Duncan applied for a charitable tax exemption covering its fifty percent ownership interest in a Houston historic home. The appraisal district denied the exemption, and the review board denied Duncan's ensuing protest. Duncan filed for judicial review. Thereafter, although Duncan House never applied for the charitable exemption for the 2018 tax year, it protested the district's 2018 appraisal on the grounds that the district court to apply the charitable exemption. The review board denied the protest. Duncan then amended its trial court petition to challenge the denial of the 2018 exemption. The trial court dismissed the 2018 claim for want of jurisdiction, and the court of appeals affirmed. The Supreme Court reversed, holding that the court of appeals erred in holding that Duncan's failure to timely apply for the 2018 exemption precluded it from receiving that exemption even if it ultimately qualified for the 2017 exemption. View "Duncan House Charitable Corp. v. Harris County Appraisal District" on Justia Law