Justia Texas Supreme Court Opinion Summaries

The case involves Yvondia Johnson, a 100% disabled U.S. Air Force veteran, who applied for a residence homestead tax exemption for her principal residence in Converse, Texas. The Bexar Appraisal District denied her application because her husband, also a 100% disabled U.S. military veteran from whom she is separated, claimed the same exemption for his principal residence in San Antonio, Texas.The trial court granted summary judgment for the appraisal district, arguing that Ms. Johnson was ineligible for the exemption because her husband claimed the same exemption on a different home they jointly owned. Ms. Johnson appealed, and the court of appeals reversed the decision, ruling in her favor.The Supreme Court of Texas affirmed the judgment of the court of appeals. The court held that the Tax Code bestows the exemption on each individual 100% disabled veteran who meets the express statutory requirements without regard to whether the veteran’s spouse also claims the exemption on a separate residence homestead. The court found that the plain text of Section 11.131(b) of the Tax Code unambiguously states that a 100% disabled veteran is entitled to a tax exemption for his or her residence homestead. The court concluded that Ms. Johnson satisfies the express, unambiguous requirements of Section 11.131(b) and therefore is entitled to the benefit of the tax exemption for 100% disabled veterans. View "BEXAR APPRAISAL DISTRICT v. JOHNSON" on Justia Law

A roofing contractor in Texas, Stonewater Roofing, Ltd. Co., filed a lawsuit against the Texas Department of Insurance and its Commissioner, Cassie Brown, seeking to invalidate Texas’s licensing and dual-capacity regulations for public insurance adjusters. Stonewater, which is not a licensed public insurance adjuster, argued that these laws violated free speech and due process rights under the First and Fourteenth Amendments of the U.S. Constitution. The trial court dismissed the case, siding with the state regulator, who argued that the laws regulated professional conduct, not speech, and that Stonewater failed to state valid void-for-vagueness claims under the Fourteenth Amendment’s Due Process Clause.The Court of Appeals for the Seventh District of Texas reversed the trial court's decision, holding that the regulations triggered First Amendment scrutiny because the business of public insurance adjusting necessarily involves speech. The court also held that Stonewater’s vagueness challenges survived because the Public Insurance Adjusters Act did not clearly proscribe Stonewater’s alleged conduct.The Supreme Court of Texas reversed the court of appeals' judgment. The court held that the challenged statutes do not regulate or restrict speech but, rather, representative capacity with a nonexpressive objective: employment to act on behalf of an insured in negotiating for or effecting the settlement of a claim. The court also held that the statutes are clear enough in proscribing Stonewater’s alleged conduct to preclude both its as-applied and facial vagueness challenges. The court concluded that Stonewater failed to state cognizable First and Fourteenth Amendment speech and vagueness claims, and therefore, the trial court properly granted the state regulator's dismissal motion. View "TEXAS DEPARTMENT OF INSURANCE v. STONEWATER ROOFING, LTD. CO" on Justia Law

The Supreme Court of Texas reviewed a case involving Samson Exploration, LLC and several families, including the Bordages, from whom Samson held oil-and-gas leases. The families sued Samson for unpaid royalties under those leases. The Bordages claimed that they were entitled to late charges on the late charges, arguing that the leases' Late Charge Provision imposed late charges on late charges, compounding them each month. Samson disagreed, asserting that the late charges were not compounded.Previously, the trial court found Samson liable for breach of contract and awarded the Bordages $12,955,919 in contract damages, based on the interpretation of the Late Charge Provision. The Bordages argued that collateral estoppel prevented the Supreme Court from deciding whether the Late Charge Provision calls for simple or compound interest because that issue was previously resolved in another case involving Samson and a different lessor, the Hooks case.The Supreme Court of Texas held that Texas law disfavors compound interest, and an agreement for interest on unpaid amounts is an agreement for simple interest absent an express, clear, and specific provision for compound interest. The court also held that Samson’s prior litigation of the issue does not collaterally estop it from asserting its claims here. The court reversed the judgment of the court of appeals and remanded the case to the trial court for further proceedings. View "SAMSON EXPLORATION, LLC v. BORDAGES" on Justia Law

A nuisance lawsuit was brought by neighbors against two poultry farms located on a single tract of rural land in Henderson County, southeast of Dallas. The neighbors claimed that the odors from the farms were a nuisance, causing them discomfort and annoyance. A jury found that the odors were a temporary nuisance and the trial court granted permanent injunctive relief that effectively shut down the farms. The farm owners and operators appealed, challenging the injunction on three grounds: whether the trial court abused its discretion in finding imminent harm; whether equitable relief was unavailable because damages provide an adequate remedy; and whether the scope of the injunction is overly broad.The Supreme Court of Texas upheld the trial court’s authority to grant an injunction, rejecting the first two challenges. However, the court concluded that the trial court abused its discretion in crafting the scope of the injunction, which was broader than necessary to abate the nuisance. The court therefore reversed in part and remanded for the trial court to modify the scope of injunctive relief. View "HUYNH v. BLANCHARD" on Justia Law

The Supreme Court of Texas reviewed a case involving the State of Texas, Ken Paxton in his official capacity as Attorney General of Texas, the Texas Medical Board, and Stephen Brint Carlton in his official capacity as Executive Director of the Texas Medical Board (collectively, the State) against a group of women and physicians. The plaintiffs challenged the constitutionality of Texas's abortion laws, specifically the Human Life Protection Act, which generally prohibits performing an abortion except when a pregnant woman has a life-threatening physical condition that poses a risk of death or serious physical impairment unless an abortion is performed.The case reached the Supreme Court of Texas as a direct appeal from a temporary injunction issued by the 353rd District Court, Travis County, Texas, which halted the enforcement of Texas's abortion laws in various circumstances. The State contested the injunction, arguing that the plaintiffs lacked standing, the State had sovereign immunity, and the current Texas law permitting life-saving abortion was not more limiting than the Texas Constitution permits.The Supreme Court of Texas held that one of the plaintiffs, Dr. Damla Karsan, had standing to challenge the Attorney General’s enforcement of the Human Life Protection Act against her. The court also concluded that the Declaratory Judgments Act waives the State’s immunity for a claim that a statute violates the state constitution. The court further clarified that under the Human Life Protection Act, a woman with a life-threatening physical condition and her physician have the legal authority to proceed with an abortion to save the woman’s life or major bodily function, in the exercise of reasonable medical judgment and with the woman’s informed consent. The court concluded that Dr. Karsan had not demonstrated that the part of the Human Life Protection Act that permits life-saving abortion is narrower than the Texas Constitution allows. As a result, the court vacated the lower court's injunction order. View "State v. Zurawski" on Justia Law

The case involves Rachel Goldstein and James Sabatino, who had a two-year relationship in Massachusetts that ended in 2017. In March 2020, Sabatino began contacting Goldstein, informing her that he had found sexually explicit photos and conversations on a cell phone she had loaned him during their relationship. Despite Goldstein's request for Sabatino to return the phone, he refused. Goldstein became concerned that Sabatino would use these texts and images to control her and ruin her career. In May 2020, a Massachusetts court granted Goldstein a protective order against Sabatino, which he violated, leading to his arrest. In June, the Massachusetts court extended the protective order for another six months. The same month, Goldstein moved to Harris County, Texas. While the Massachusetts protective order was still in effect, Sabatino began filing small-claims lawsuits in Massachusetts against Goldstein. In October 2020, Goldstein filed an application for a protective order against Sabatino in Harris County.The district court in Harris County issued a protective order against Sabatino, a Massachusetts resident, based on conduct that occurred entirely within Massachusetts. Sabatino appealed, challenging the district court's personal jurisdiction over him and its subject matter jurisdiction over the proceeding. The Court of Appeals for the First District of Texas vacated the order and dismissed the case, holding that the district court lacked territorial jurisdiction—a purportedly nonwaivable, third jurisdictional requirement. The court of appeals did not address personal jurisdiction.The Supreme Court of Texas disagreed with the court of appeals’ territorial jurisdiction analysis, but agreed with Sabatino that the district court lacked personal jurisdiction over him. The court held that territorial jurisdiction is not an independent jurisdictional requirement in Chapter 7B protective-order proceedings. The court also held that Sabatino did not enter a general appearance, and thus did not waive his challenge to the district court's personal jurisdiction. Therefore, the Supreme Court of Texas affirmed the court of appeals’ judgment vacating the protective order and dismissing the case. View "GOLDSTEIN v. SABATINO" on Justia Law

The case involves Sunny Letot, who owned a vintage Mercedes-Benz sedan that was rear-ended by a driver insured by USAA Casualty Insurance Company. USAA determined that the cost of repair exceeded the car's pre-collision value and deemed it a "total loss" or "salvage." USAA sent Letot checks to cover the car’s pre-collision value and eight days of lost use. Without waiting for Letot to accept its offer, USAA reported to the Texas Department of Transportation (TxDOT) that Letot’s car was salvage. Letot disagreed with USAA’s determinations and never cashed its proffered checks. She claims that USAA’s premature filing led TxDOT to invalidate her vehicle’s regular title, which prevented her from using or selling her sedan. Letot argued that USAA’s actions constituted conversion of her car.The district court certified a class of claimants whose cars USAA had deemed salvage and about whom USAA filed a report within three days of sending the claimant a check for the salvage vehicle. The class sought injunctive relief and damages. The court of appeals affirmed the class certification.The Supreme Court of Texas concluded that class certification was impermissible in this case. The court found that neither Letot nor any class member had standing to pursue injunctive relief, so Letot could not litigate an individual claim for an injunction, much less represent a class. Letot did, however, have standing to seek damages. But as to damages, the certified class did not satisfy the requirements of predominance or typicality. The court reversed the court of appeals’ judgment and remanded the case to the trial court to resolve Letot’s individual claim. View "USAA CASUALTY INSURANCE COMPANY v. LETOT" on Justia Law

The case revolves around a dispute between Anne Carl and related parties (the royalty holders) and Hilcorp Energy Company (the producer) over the calculation of royalties from a mineral lease. The lease stipulates that royalties are to be calculated based on the market value of the minerals "at the well," meaning before any post-production efforts have increased their value. However, the minerals are often not sold until after these efforts have taken place, resulting in a higher sale price. To account for this disparity, the producer deducted the proportionate share of post-production costs from the royalty payment, a method known as the "workback method." The royalty holders were dissatisfied with this reduced payment and sued, arguing that the lease required payment of a royalty on all gas produced from the well.The case was initially heard in a federal district court, which sided with the producer. The court found that the lease did indeed convey an "at-the-well" royalty, meaning the royalty holders were obligated to share proportionately in the post-production costs. The court also found no fault with the producer's method of accounting for these costs, which involved using some of the gas produced from the well to power post-production activities conducted off the lease. The value of this gas was considered a post-production cost and was therefore deducted from the total volume of gas used to calculate the royalty.The case was then certified to the Supreme Court of Texas, which affirmed the lower court's decision. The court agreed with the producer's interpretation of the lease and found that the royalty holders, as holders of an "at-the-well" royalty, were indeed obligated to bear their usual share of post-production costs. The court also found that the producer's method of accounting for these costs was permissible. The court concluded that the royalty holders were not shortchanged and that the producer's calculation was one acceptable way to convert the downstream sales price into an at-the-well market value on which to pay the royalty, as required by the lease. View "CARL v. HILCORP ENERGY COMPANY" on Justia Law

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