Justia Texas Supreme Court Opinion Summaries

In this contract dispute, the Supreme Court reversed the judgment of the court of appeals reversing the trial court's grant of summary judgment for Defendants, holding that, under the statute of frauds, the proffered contract was not enforceable and Defendants could not be liable for breach of it.The parties to this dispute sent several e-mails prior to the anticipating signing of a formal written agreement, which was never executed. Plaintiffs, however, claimed that the e-mails, taken together, amounted to an enforceable written contract that satisfied the statute of frauds. Plaintiffs sued for breach of the alleged contract and for tortious interference. The trial court granted summary judgment for Defendants on all claims. The court of appeals reversed as to the breach of contract claim, concluding that the e-mails satisfied the statute of frauds and amounted to a contract enforceable against Defendants. The Supreme Court reversed the court of appeals' judgment on the contract claims, holding that there was no written memorandum which was complete within itself in every material detail, as required by the statute of frauds. View "Copano Energy, LLC v. Bujnoch" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the judgment of the trial court concluding that Petitioners (together, ETP) and Respondents (together, Enterprise) had created a partnership to market and pursue a pipeline project to transport crude oil from Oklahoma to the Gulf Coast, holding that Texas law permits parties to conclusively agree that, as between themselves, no partnership will exist unless certain conditions are satisfied.In three written agreements, the parties set forth their intent that neither party be bound to proceed with the project at issue until each company's board of directors had approved the execution of a formal contract and definitive agreements memorializing the terms and conditions of the transactions were executed and delivered. ETP later sued arguing the parties had formed a partnership to market and pursue a pipeline and that Enterprise breached its statutory duty of loyalty. The trial court entered judgment for ETP. The court of appeals reversed. The Supreme Court affirmed, holding (1) parties can conclusively negate the formation of a partnership through contractual conditions precedent; and (2) the parties did so as a matter of law in this case, and there was no evidence that Enterprise waived the conditions. View "Energy Transfer Partners, LP v. Enterprise Products Partners, LP" on Justia Law

In this property dispute between adjoining landowners the Supreme Court affirmed the decision of the court of appeals affirming the judgment of the trial court enforcing an easement, holding that a neighborhood association had standing to enforce the easement and that the evidence supported the trial court's rejection of the neighboring property owner's affirmative defenses of waiver and estoppel.Petitioner owned a parcel of undeveloped property that bordered Champee Springs Ranches neighborhood, represented here by its property owners association, and was burdened by a restrictive easement. Petitioner sought to avoid the easement to connect the property to existing public roads and to develop the parcel into a residential subdivision. To further these plans, Petitioner's predecessor built a private construction road across the easement in violation of the easement's access restriction. Champee Springs bought this lawsuit to enforce the easement. The trial court enforced the easement, and the court of appeals affirmed. The Supreme Court affirmed, holding (1) Champee Springs had standing to sue to enforce the easement; (2) the evidence supported the trial court's rejection of Petitioner's affirmative defenses; and (3) this Court declines to declare the restrictive easement void on public policy grounds. View "Teal Trading & Development, LP v. Champee Springs Ranches Property Owners Ass'n" on Justia Law

The Supreme Court reversed the judgment of the court of appeals, holding that a devise of "all...right, title and interest in and to Ranch 'Las Piedras'" referred only to a surface estate by that name, as understood by the testatrix and beneficiaries at the time the will was made, and did not include the mineral estate.Respondents asserted that their father's life estate under their grandmother's will included her interest in not only the surface of Las Piedras Ranch but also the minerals beneath it. The trial court awarded judgment in favor of Respondents. The court of appeals affirmed. The Supreme Court reversed, holding that Respondents' claims were premised on an erroneous interpretation of their grandmother's will. Therefore, Petitioners were entitled to judgment as a matter of law. View "ConocoPhillips Co. v. Ramirez" on Justia Law

In this health care liability action, the Supreme Court conditionally granted Claimant's petition for writ of mandamus and ordered the court of appeals to vacate its order ruling that Claimant was not permitted to depose a health care provider before serving him with an expert report, holding that the court of appeals erred in holding that the Medical Liability Act categorically prohibited Claimant from deposing or obtaining documents from that provider.Claimant sued one health care provider, served an expert report meeting the requirements of the Act on that provider, and then sought to depose Dr. Jeffrey Sandate, another provider involved in the underlying incident and a nonparty in the action. The court of appeals ruled that Claimant may not depose Dr. Sandate before serving him with an expert report under the Act. The Supreme Court ordered the court of appeals to vacate its order, holding that the Act did not insulate Dr. Sandate from being deposed or producing documents in this case. View "In re Comanche Turner" on Justia Law

The Supreme Court answered a question certified to it by the United States Court of Appeals for the Fifth Circuit regarding what constitutes good faith under the Texas Uniform Fraudulent Transfer Act (TUFTA) by holding that when a transferee on inquiry notice attempts to use TUFTA's affirmative defense that it acted in good faith to shield a transfer from the statute's clawback provision it must show, at a minimum, that it investigated its suspicions diligently.Creditors may invoke TUFTA to claw back fraudulent transfers from their debtors to third-party transferees, but if the transferee proves that it acted in good faith and the transfer was for a reasonably equivalent value, it may keep the transferred asset. The Fifth Circuit asked the Supreme Court whether a transferee on inquiry notice of fraudulent intent can achieve good faith without investigating its suspicions. The Supreme Court answered the question in the negative, holding that a transferee on inquiry notice of fraud cannot shield itself from TUFTA's clawback provision without diligently investigating its initial suspicions, regardless of whether a hypothetical investigation would reveal fraudulent conduct. View "Janvey v. GMAG, LLC" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the order of the trial court terminating Mother's parental rights and remanding the case for a new trial, holding that Mother was not properly admonished about her rights as required by Tex. Fam. Code 263.0061.At every permanency hearing, Mother appeared without counsel but was not further admonished about her statutory right to legal representation. The trial court subsequently terminated Mother's parental rights. Mother then filed an affidavit of indigence and a notice of appeal. After a hearing, the trial court found Mother indigent and appointed counsel to represent her on appeal. The court of appeals reversed and remanded the case for a new trial, holding that Mother was entitled to appointed counsel because there was sufficient indication in the record that she was indigent, such that the trial court should have conducted further inquiry into her status. The Supreme Court affirmed, holding (1) the court of appeals erred in holding that the trial court was required to conduct a pre-trial inquiry into Mother's indigency status; but (2) a new termination trial was required because the trial court failed to give mandatory statutory admonishments regarding the right to appointed counsel. View "In re Interest of B.C." on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming summary judgment, not on the merits, but based on remediable record-citation errors in Appellant's brief, holding that the record citation errors should not have been fatal to the appeal absent a reasonable opportunity to cure the defects.In this litigation involving the dissolution of Robbie Lesa Hames Horton and Kimberly Stovall's personal and business relationship, Horton appealed a severance order and three summary judgments. The court of appeals affirmed, primarily faulting Horton for citing to documents in the appendix of her appellate brief instead of providing citations to the clerk's record. The Supreme Court reversed, holding that Horton was entitled to, at a minimum, a reasonable opportunity to correct the defective record citations in her appendix documents, which the court of appeals knew were actually included in the summary judgment record. View "Horton v. Stovall" on Justia Law

In this dispute between the Hickman Group and the Murrin Group asserting the right to control the management of Billy Bob's the Supreme Court denied the Murrin Group's petition for writ of mandamus challenging the trial court's denial of its motion to disqualify Kelly Hart & Hallman (KHH) as counsel for Billy Bob's Texas Investments (BBT) and as counsel for the Hickman Group, holding that the Murrin Group did not establish a clear abuse of discretion as to the motion to disqualify.The Murrin Group filed the underlying lawsuit against the Hickman Group asserting claims individually by the members of the Murrin Group and claims asserted derivatively on behalf of BBT. KHH was hired to represent both the Hickman Group and BBT in the litigation. The Murrin Group moved to disqualify KHH as counsel for both BBT and the Hickman Group and filed a Rule 12 motion requiring KHH to show its authority to represent BBT. The trial court denied both motions. The Murrin Group sought mandamus relief. The Supreme Court denied relief, holding (1) the trial court properly denied the motion to disqualify; and (2) the Murrin Group did not establish the lack of an adequate remedy at law as to the Rule 12 motion. View "In re Murrin Brothers 1885, Ltd." on Justia Law

In this case examining whether the former version of the Texas Citizens Participation Act (TCPA) applies to certain counterclaims alleged in a dispute over an oil and gas lease the Supreme Court affirmed in part and reversed in part the judgment of the court of appeals dismissing all the counterclaims in this case, holding that the court of appeals properly dismissed one counterclaim but erred in dismissing the remaining counterclaims.At issue was whether each counterclaim was "based on, relates to, or is in response to" the "exercise of the right of free speech" or the "exercise of the right to petition," as defined by the governing statutory text. See Tex. Civ. Prac. & Rem. Code 27.003(a). The Supreme Court held (1) certain communications to third parties about an oil and gas lease allegedly involving the exercise of free speech, on which some of the counterclaims were based, were not covered by the TCPA because they did not relate to a matter of public concern under the TCPA, and therefore, the court of appeals erred in dismissing these counterclaims; and (2) the court of appeals correctly disposed of the "right to petition" counterclaim. View "Creative Oil & Gas, LLC v. Lona Hills Ranch, LLC" on Justia Law