Justia Texas Supreme Court Opinion Summaries

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

The Supreme Court reversed the judgment of the court of appeals holding that the federal Foreign-Trade Zones Act's exemption of goods imported from outside the United States and held within a zone for certain purposes from state and local ad valorem taxation did not apply to Petitioner's imported crude oil and refinery products, holding that the exemption did apply in this case.The Act provides for the designation of duty-free areas of operation in or near the United States ports of entry. The court of appeals concluded that the Act's exemption at issue in this case did not apply to Petitioner's products because the zone involved was not activated at the time. Harris County petitioned the appraisal review board for a determination that Petitioner's operations in Subzone 84-N were not tax-exempt. The appraisal board denied relief, and Harris County brought this action for judicial review. The trial court granted summary judgment for Petitioner. The court of appeals reversed, concluding that Petitioner's inventory was not entitled to exemption from ad valorem taxation. The Supreme Court affirmed, holding that Subzone 84-R was activated during the tax years at issue, and therefore, the ad valorem tax exemption applied to Petitioner's inventory. View "PRSI Trading, LLC v. Harris County, Texas" on Justia Law

In this dispute over whether an email exchange reflected the meeting of minds required for a contract the Supreme Court reversed the judgment of the court of appeals reversing the trial court's grant of summary judgment in favor of the Sellers after concluding that the parties did not intend to be bound to any agreement, holding that, as a matter of law, the parties did not execute and deliver a definitive agreement.The Sellers agreed to develop and sell certain assets worth hundreds of millions of dollars. The Sellers and Le Norman Operating LLC (LNO) exchanged a number of emails regarding the purchase of the assets, but the Sellers elected to sell the assets to another entity. LNO brought this breach of contract alleging that the Sellers breached an alleged contract entered into through the email exchange. The trial court granted summary judgment for the Sellers, concluding that there was no meeting of the minds. The court of appeals reversed, concluding that whether LNO and the Sellers intended to b abound by the terms set forth in the exchanged emails were fact issues precluding summary judgment. The Supreme Court reversed, holding that the emails did not constitute a definitive agreement. View "Chalker Energy Partners III, LLC v. Le Norman Operating LLC" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals concluding that Tex. R. Civ. P. 91a permits dismissal based on an affirmative defense and that the alleged destruction of evidence is an action "taken in connection with representing a client in litigation," thus entitling the defendant attorneys to attorney immunity.Plaintiff hired Defendants to represent her in a lawsuit. Plaintiff later sued Defendants for, inter alia, fraud, trespass to chattel, and conversion, alleging that Defendants intentionally destroyed key evidence in the case. Defendants moved to dismiss the case under Rule 91a, claiming that it was entitled to attorney immunity on all of Plaintiff's claims. The trial court granted the motion and dismissed the case. Plaintiff appealed, arguing that affirmative defenses such as attorney immunity cannot be the basis of a Rule 91a dismissal and that Defendants were not entitled to attorney immunity. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Rule 91a permits motions to dismiss based on affirmative defenses "if the allegations, taken as true, together with inferences reasonably drawn from them, do not entitle the claimant to the relief sought"; and (2) because Defendants' allegedly wrongful conduct involved the provision of legal services that conduct was protected by attorney immunity. View "Bethel v. Quilling, Selander, Lownds, Winslett & Moser, P.C." on Justia Law

In this negligence action, the Supreme Court held that an agreed scheduling order setting expert report deadlines, with no reference to Tex. Civ. Prac. & Rem. Code 128.053(a), did not extend the statutory deadline to serve an expert report and that Plaintiffs' failure timely to serve an expert report entitled the shooting range's employee to seek dismissal.Plaintiffs sued a shooting range and its employee alleging negligence. The parties submitted to an agreed scheduling order, but the order did not specifically reference section 128.053. More than ninety days after Plaintiffs filed suit Defendants filed a motion to dismiss. The trial court denied dismiss, ruling that the agreed scheduling order extended Plaintiffs' section 128.053 deadline. The court of appeals dismissed all claims against the shooting range but allowed the claims against the employee to proceed on the basis that section 128.053(b)(2) does not apply to a shooting range employees. The Supreme Court held (1) the shooting range was correctly dismissed from the suit because the agreed scheduling order did not extend Plaintiffs' deadline to serve the expert report section 128.053 requires; and (2) the employee was entitled to dismissal with prejudice under section 128.053(b)(2) as an implicated defendant whose conduct was required to be addressed in an expert report. View "Shinogle v. Whitlock" on Justia Law

The Supreme Court held that the corporation alleging a healthcare liability claim against a hospital in this case fell within the Texas Medical Liability Act's definition of "claimant" under Tex. Civ. Prac. & Rem. Code 74.351(a) and that the allegations stated a health care claim against the hospital, and therefore, the corporation was required to submit an expert report supporting the claim.A bridal shop in Ohio was required to close when health authorities learned that a nurse at the Dallas Presbyterian Hospital who had visited the bridal shop was diagnosed as having the Ebola virus. The shop's owner sued the hospital, alleging that the hospital's negligence in failing to prevent transmission of the Ebola virus to the nurse caused the shop to close permanently due to health concerns and adverse publicity. Invoking the Act, the hospital moved to dismiss the claims because the owner failed to submit an expert report detailing a factual basis for its healthcare liability claim. The trial court denied the motion. The court of appeals reversed. The Supreme Court affirmed, holding that the business's claims that the hospital's departure from accepted safety standards caused its injury stated a healthcare liability claim under the Act and that the business was a claimant under the Act. View "Coming Attractions Bridal v. Texas Health Resources" on Justia Law

In this case involving a written assignment of an overriding royalty interest in minerals produced from land in Wheeler County the Supreme Court reversed the judgment of the court of appeals reversing the trial court's judgment declaring that the assignment conveyed an overriding royalty interest in all production under the lease, holding that the assignment unambiguously conveyed the assignor's overriding royalty interest in all production under the lease.The assignment in this case identified the single well that was producing at the time of the assignment, the land on which the well was located, and the lease under which the overriding royalty interest existed. At issue was whether the assignment conveyed the assignor's interest in all production under the identified lease or only in production from the identified well or from any well drilled on the identified land. The court of appeals held that the assignment conveyed only the 3.75 percent overriding royalty interest in production from the tract of land on which the well was located. The Supreme Court reversed, holding that the assignment unambiguously conveyed all of the interest that the assignor owned at the time of the conveyance. View "Piranha Partners v. Neuhoff" on Justia Law