Justia Texas Supreme Court Opinion Summaries

Westwood Motorcars, LLC leased commercial property in Dallas to operate an automobile dealership. The lease was set to expire in 2013, but an addendum allowed Westwood to extend the lease for two additional 24-month terms. In 2015, ownership of the property changed hands and Virtuolotry, LLC became the new landlord. Westwood sought to exercise its option to extend the lease for the second additional term, but Virtuolotry’s lawyers refused, asserting that Westwood had breached the lease in numerous ways. Amidst this dispute, Westwood claimed that Virtuolotry and its manager, Richard Boyd, harassed Westwood at the premises, interfering with its business operations. Westwood sued Virtuolotry in district court, seeking a declaratory judgment that it had not breached the lease and that it had properly extended the lease for another two years. Virtuolotry sued in justice court to evict Westwood for unpaid rent, lease violations, and holding over unlawfully.The justice court ruled in favor of Virtuolotry, awarding it "possession only." Westwood appealed the judgment to the county court at law. However, a few weeks before the trial date, Westwood formally withdrew its appeal in county court, and the county court entered a “stipulate[d] and agree[d]” judgment ordering “that possession of the Premises is awarded” to Virtuolotry. Westwood fully vacated the property, but continued its pending suit in district court, adding claims for breach of contract (against Virtuolotry) and constructive eviction (against Virtuolotry and Boyd). The district court ruled in favor of Westwood, awarding damages and attorney’s fees.Virtuolotry and Boyd appealed, and the court of appeals reversed the district court's decision, ruling that by agreeing to the eviction-suit judgment in county court, Westwood “voluntarily abandoned the premises” and thus “extinguish[ed] any claim for damages.” Westwood then petitioned the Supreme Court of Texas for review.The Supreme Court of Texas reversed the court of appeals' decision, ruling that the court of appeals erred by giving a judgment of possession from a court of limited jurisdiction preclusive effect over Westwood’s claim for damages in district court. The Supreme Court of Texas held that Westwood’s agreement to entry of the county-court judgment cannot reflect assent to anything more than what that judgment resolves—i.e., who receives immediate possession of the property. The court remanded the case to the court of appeals for further proceedings. View "WESTWOOD MOTORCARS, LLC v. VIRTUOLOTRY, LLC" on Justia Law

This case involves a dispute over the interpretation of an assignment of mineral rights. In 1987, Shell Western E&P, Inc. sold a large bundle of Texas oil-and-gas properties to the predecessor of Citation 2002 Investment LLC. The assignment included an exhibit that listed the properties being transferred, some of which included depth specifications. In 1997, Shell purported to assign all its interests in the same leases to Occidental Permian’s predecessor. Occidental claimed that Shell had reserved to itself interests beyond the depth specifications of the 1987 assignment. Citation, however, claimed that it received the entirety of Shell’s leasehold interests in the 1987 assignment.The trial court granted Occidental’s motion for summary judgment, concluding that the depth-specified tracts listed in the exhibit reserved to Shell the mineral-estate depths beyond the notations. Citation appealed, and the court of appeals reversed, holding that the 1987 assignment unambiguously conveyed the entirety of Shell’s interests in the leasehold estates without reserving portions of those interests to Shell.The Supreme Court of Texas affirmed the court of appeals' decision. The court held that the disputed assignment unambiguously conveyed all right, title, and interest that Shell owned in the leasehold estates listed in the exhibit, without reserving portions of those interests to itself through further notations about specific tracts within those estates. The court reasoned that the assignment's broad granting language, coupled with the absence of explicit reservation language, indicated that the entirety of the leasehold interests were conveyed. The court also noted that the depth specifications in the exhibit served a concrete purpose of providing notice of depth-specific third-party interests that continue after the leasehold estates are assigned. View "OCCIDENTAL PERMIAN, LTD. v. CITATION 2002 INVESTMENT LLC" on Justia Law

Mark and Birgit Self owned a tract of rural land that adjoined a portion of Farm-to-Market Road 677 in Montague County, Texas. The Texas Department of Transportation (TxDOT) had a right-of-way easement that reached fifty feet from the centerline of the road in each direction, which burdened part of the Selfs’ property. As part of a highway maintenance project, TxDOT contracted with T.F.R. Enterprises, Inc. (TFR) to remove brush and trees from the right-of-way. TFR subcontracted with Lyellco Inc. to remove the trees. Following TxDOT’s instruction to TFR to “clear everything between the fences,” Lyellco workers cut all trees up to the Selfs’ fence line, including trees that were outside the State’s right-of-way easement. The Selfs sued TxDOT for negligence and inverse condemnation.The trial court denied TxDOT’s plea to the jurisdiction, asserting immunity from both causes of action. On appeal, the court of appeals affirmed in part and reversed in part. It held that there was a fact issue on whether the Texas Tort Claims Act waived immunity for the negligence cause of action, but reversed the trial court’s judgment on the cause of action for inverse condemnation, holding there was no evidence that TxDOT intentionally destroyed the Selfs’ property.The Supreme Court of Texas disagreed with the court of appeals. It held that the Selfs had not shown either that the subcontractor’s employees were in TxDOT’s paid service or that other TxDOT employees operated or used the motor-driven equipment that cut down the trees, as required to waive immunity under the Tort Claims Act. Therefore, the negligence cause of action was dismissed. However, regarding inverse condemnation, the court found that the Selfs had alleged and offered evidence that TxDOT intentionally directed the destruction of the trees as part of clearing the right-of-way for public use. Therefore, the cause of action for inverse condemnation was remanded to the trial court for further proceedings. View "TEXAS DEPARTMENT OF TRANSPORTATION v. SELF" on Justia Law

This case involves a dispute between a lawyer, George Fleming, and his former clients, referred to as the "Wilson plaintiffs". Fleming had represented over 8,000 plaintiffs in a mass-tort action against the manufacturer of a diet pill known as "fen-phen". The Wilson plaintiffs are about 4,000 of Fleming’s former clients. Fleming had spent roughly $20 million to medically screen over 40,000 potential claimants, about 20% of whom became his clients. In 2006, Fleming settled the case for $339 million and reimbursed himself for the costs of the screenings by deducting that amount from the settlement funds. He charged his clients not just for their own medical-screening costs but also for those of approximately 32,000 people who never became his clients and who did not participate in the underlying case. This financial choice led to further litigation, with Fleming as the defendant in various actions brought by his former clients.In the lower courts, Fleming successfully opposed a motion for class certification in a federal court case brought by two of his former clients, arguing that the claims of his former clients were not sufficiently common for aggregate treatment. After the denial of class certification, another group of about 650 former clients sued Fleming for breaches of contract and fiduciary duty. Following a verdict against Fleming in this case, the Wilson plaintiffs moved for summary judgment on the ground that the verdict collaterally estopped Fleming from contesting the merits of their claims against him. Fleming successfully opposed that motion, arguing that the issues presented by the other plaintiffs were not identical to those of the Wilson plaintiffs. The trial court denied the Wilson plaintiffs’ motion for summary judgment without explanation. Later, Fleming moved for summary judgment, asserting defensive collateral estoppel against the Wilson plaintiffs.The Supreme Court of Texas affirmed the judgment of the court of appeals, but for a different reason. The court concluded that Fleming was judicially estopped from establishing an essential component of his summary-judgment motion. The court found that Fleming's assertions in prior litigation clearly and unequivocally contradicted his summary-judgment motion’s assertions regarding whether the Wilson plaintiffs’ legal and factual positions were materially identical to those of the other plaintiffs. The court held that Fleming was estopped from asserting that the thousands of remaining plaintiffs’ claims were materially indistinguishable. View "FLEMING v. WILSON" on Justia Law

The case revolves around a dispute between the Texas Windstorm Insurance Association (TWIA) and Stephen Pruski, a policyholder. TWIA is a quasi-governmental body that provides windstorm and hail insurance to property owners in the coastal region of Texas who cannot get this coverage in the regular market due to the risk of catastrophic hurricanes. Pruski filed two claims with TWIA after Hurricane Harvey and a subsequent storm, and TWIA partially accepted and partially denied coverage for both claims. Pruski then filed a lawsuit in Nueces County District Court, seeking damages for TWIA’s alleged improper denial of coverage. The case was assigned to a judge who was not appointed by the Judicial Panel on Multidistrict Litigation (MDL), as required by Texas Insurance Code Section 2210.575(e).The case was initially heard in the Nueces County District Court, where TWIA filed a motion for summary judgment, arguing that the damages for which Pruski sought recovery were not covered by his policy as a matter of law. The district court granted the motion and rendered a final, take-nothing judgment for TWIA. Pruski appealed, arguing that the trial judge was not qualified to render judgment because she had not been appointed by the MDL panel. The court of appeals reversed the district court's judgment, holding that a trial judge who is not appointed by the MDL panel is “without authority to render judgment” in a suit under Chapter 2210.The Supreme Court of Texas disagreed with the court of appeals' interpretation of the statute. The court held that while the requirement for a judge to be appointed by the MDL panel is mandatory, it is not jurisdictional. Therefore, the district court had subject matter jurisdiction over the suit, even though the presiding judge was not appointed by the MDL panel. The Supreme Court of Texas reversed the court of appeals’ judgment and remanded the case to that court for further proceedings. View "TEXAS WINDSTORM INSURANCE ASSOCIATION v. PRUSKI" on Justia Law

The case revolves around a dispute between Harley Channelview Properties, LLC (Channelview) and Harley Marine Gulf, LLC (Harley Marine) over a property lease agreement. The original lease, signed in 2011, included a provision granting Harley Marine an option to purchase the property. In 2012, Channelview bought the property, subject to the Harley Marine lease. Over time, Channelview concluded that Harley Marine's purchase option had expired, and it invested $15 million in property improvements. However, Harley Marine believed the purchase option was still valid and attempted to buy the property in 2020. When Channelview refused to transfer the property, Harley Marine sued for breach of contract and sought specific performance.The trial court granted Harley Marine's motion for partial summary judgment on its contract claim and ordered Channelview to transfer the property title to Harley Marine within 30 days, even though the court acknowledged that its ruling was "interlocutory" and other issues remained unresolved. Channelview appealed, arguing that the trial court's order was equivalent to a temporary injunction.The court of appeals dismissed Channelview's appeal, ruling that the trial court had granted "permanent" relief, and thus the order was not a "temporary" injunction from which an appeal could be taken. Channelview then petitioned the Supreme Court of Texas for review.The Supreme Court of Texas reversed the court of appeals' decision. The court held that the trial court's order had the character and function of a temporary injunction because it required immediate action based on an interim ruling that a claim had merit and was effective during the pendency of the suit. The court noted that the order was "interlocutory," not final, and the trial court could modify it at any time until final judgment. The court remanded the case to the court of appeals for consideration of the merits of the appeal. View "HARLEY CHANNELVIEW PROPERTIES, LLC v. HARLEY MARINE GULF, LLC" on Justia Law

The Supreme Court of Texas was asked to consider whether Texas Rules of Evidence 509(e)(4) and 510(d)(5) apply to a discovery request for a minor plaintiff’s psychological treatment records. The minor, E.B., was seeking damages for mental anguish she suffered from witnessing her younger brother's death in an ATV accident. The ATV was sold by Richardson Motorsports, who requested all of E.B.’s psychological treatment records from her clinical psychologist and pediatrician. The court had to decide whether E.B.’s mental or emotional condition was part of her negligence claim for mental anguish damages or Richardson’s defense that post-accident causes contributed to E.B.’s anguish, thus making her psychological records discoverable under the privilege exceptions.The trial court denied E.B.’s motions to quash the discovery request and ordered that all of E.B.’s requested psychological records be produced to Richardson. E.B. and her mother then filed a petition for writ of mandamus in the court of appeals, which conditionally granted relief and directed the trial court to vacate its orders denying their motions to quash and requiring disclosure of the records. The court of appeals held that the records are privileged and the exceptions do not apply because E.B.’s pleadings make no more than a routine claim of mental anguish.The Supreme Court of Texas concluded that E.B.’s mental or emotional condition is part of her claim because she is relying on expert testimony about that condition to prove her mental anguish damages, and it is also part of Richardson’s defense that those damages have alternative causes. Thus, discovery of E.B.’s mental health care treatment records relevant to the claim or defense is not foreclosed by privilege. The court therefore conditionally granted mandamus relief and directed the court of appeals to withdraw its mandamus order preventing discovery. The court also noted that discovery of some records may be permitted on privilege-waiver grounds and further trial court proceedings are necessary to determine which parts of the records are not privileged under each rule. View "IN RE RICHARDSON MOTORSPORTS, LTD." on Justia Law

The case involves a dispute between Lakeside Resort JV, LLC, the owner of Margaritaville Resort Lake Conroe, and a guest, Mendez, who claimed to have sustained severe bodily injuries after stepping into a deep hole on the property. Mendez sued Lakeside for premises liability and negligence, seeking monetary relief between $200,000 and $1,000,000, along with pre-judgment and post-judgment interest, court costs, and expenses. Lakeside failed to timely answer the lawsuit due to an alleged failure by its registered agent for service of process to send a physical copy of the service and misdirect an electronic copy. Mendez then moved for a default judgment, which was granted by the district court.The district court signed a "Final Default Judgment" proposed by Mendez's counsel, which awarded Mendez damages exceeding the $1 million upper limit stated in her original petition. The judgment concluded with the language: "This Judgment finally disposes of all claims and all parties, and is not appealable." Lakeside, unaware of the suit, did not respond before or after the judgment was signed. After the time for a restricted appeal had run, Mendez requested an abstract of judgment and began execution. Lakeside, upon learning of the suit and resulting judgment, filed an answer containing a general denial, a motion to rescind abstract of judgment, and a combined motion to set aside the default judgment and for a new trial. The district court denied Lakeside’s motions, concluding that the judgment was final and that its plenary power had therefore expired.The Supreme Court of Texas held that the default judgment was not final despite being labeled as a "Final Default Judgment." The court reasoned that the judgment's assertion of non-appealability did not just prevent it from unequivocally expressing an intent to finally dispose of the case—it expressly and affirmatively undermined or contradicted any such intent. The court conditionally granted mandamus relief and directed the trial court to vacate the challenged orders that were predicated on that court’s conclusion that its prior judgment is final. View "IN RE LAKESIDE RESORT JV, LLC" on Justia Law

The case involves the City of Houston, which appealed a wrongful-death suit filed by the family of Dwayne Foreman, who was killed in a collision with a police cruiser. The police officers were responding to a suicide call at the time of the accident. The City argued that it was immune from the lawsuit because the officer was performing a discretionary duty in good faith and within the scope of his authority.The trial court denied the City's motion for summary judgment, and the City appealed. The court of appeals affirmed the trial court's decision, holding that a fact issue existed on the officer’s good faith, which precluded summary judgment.The Supreme Court of Texas disagreed with the lower courts. It held that, as a matter of law, the officer was performing a discretionary duty while acting within the scope of his authority in responding to the emergency call and was acting in good faith. The court reasoned that a reasonably prudent officer in the same or similar circumstances could have believed the actions were justified. Therefore, the court reversed the lower courts' decisions and dismissed the case. View "CITY OF HOUSTON v. SAULS" on Justia Law

The case revolves around a family dispute over the management of a trust established by Bernard and Jeannette Fenenbock. The trust was divided into three sub-trusts (Trust A, Trust B, and Trust C) to benefit their children, Glenna Fenenbock Gaddy and Mark Fenenbock. After Bernard's death, Glenna began serving as co-trustee with her mother Jeannette. Upon Jeannette's death, Glenna transferred shares from the sub-trusts to her own trust and sold them to her sons, Weston and Lane. Mark filed a lawsuit against Glenna, asserting that she had breached her duties as a trustee by transferring the shares without his approval as a co-trustee.The probate court ruled in favor of Mark, declaring that Mark is a co-trustee and that the transfer of shares to Glenna's Trust was void. The court ordered that the shares be restored to the sub-trusts. Glenna appealed this decision, and the court of appeals vacated the probate court’s order, concluding that the buyers of the shares, Weston and Lane, were “jurisdictionally indispensable parties” whose absence deprived the probate court of jurisdiction.The Supreme Court of Texas disagreed with the court of appeals, holding that the probate court had jurisdiction but erred by ordering Glenna to restore property she no longer owns or controls. The court reversed the court of appeals’ judgment vacating the probate court’s order, reversed the probate court’s order, and remanded the case to the probate court for further proceedings. The court noted that any appropriate relief must come from Glenna or Glenna’s Trust or through the ultimate distribution of the assets remaining in the Sub-Trusts. View "IN THE MATTER OF TRUST A AND TRUST C. ESTABLISHED UNDER THE BERNARD L. AND JEANNETTE FENENBOCK LIVING TRUST AGREEMENT" on Justia Law