Justia Texas Supreme Court Opinion Summaries

The prohibition in Texas Fam. Code 231.211(a) that courts may not assess costs at the conclusion of a Title VI-D case against a party who was provided services by the Title IV-D agency applies to courts of appeals.Shana Williams filed a suit that resulted in a determination that Christopher Spates was the father of Williams’ child and an order that he pay child support. The trial court later signed a modification order that retroactively reduced Spates’s child support obligation. Williams subsequently moved successfully to void the modification order based on a procedural anomaly. The court of appeals reinstated the modification order and assessed court costs against Williams. The Office of the Attorney General (OAG) moved for rehearing regarding the assessment of costs, arguing that section 231.211(a) prohibited the assessment. The court of appeals denied the motion on the grounds that the prohibition does not apply to appellate courts. The Supreme Court reversed on this issue, holding that the OAG has statutory standing to bring this appeal and that section 231.211(a)’s prohibition of the assessment of fees and costs applies to both trial courts and appellate courts. View "In re C.Y.K.S." on Justia Law

The Texas-residency exception that excludes certain claims from the forum non conveniens doctrine because the claims are prosecuted by a Texas-resident plaintiff or derivative of a Texas decedent applied to some of Plaintiffs’ underlying claims in this case.Venice Alan Cooper was killed while working on his Mahindra tractor at his home in Mississippi. The tractor was sold to the decedent in Mississippi. Plaintiffs, the decedent’s sons and Texas residents, filed a negligence and products liability action in Texas against Mahindra USA, Inc., the tractor’s vendor. Mahindra filed a motion to dismiss based on forum non conveniens. The trial court denied the motion to dismiss. The Supreme Court held that the trial court did not abuse its discretion when ruling on the motion because the Texas-residency exception to the forum non conveniens doctrine applied to some of Plaintiffs’ underlying claims. View "In re Mahindra, USA Inc." on Justia Law

In this insurance dispute, the Supreme Court held that the issue of whether the trial court properly disregarded some of the jury’s findings should be remanded to the court of appeals for reconsideration in light of this Court’s decision in USAA Texas Lloyds Co. v. Menchaca, __ S.W.3d __ (Tex. 2018).Plaintiffs sued their insurer, State Farm, for breach of contract and Insurance Code violations. The jury found that both parties breached the insurance contract but that Plaintiffs breached first. The jury then awarded damages for State Farm’s breach of the policy and for Plaintiffs’ extra-contractual claims. The trial court disregarded two of the jury’s findings about Plaintiffs’ breach of the insurance contract and rendered judgment for Plaintiffs. The court of appeals affirmed. While State Farm's appeal was pending, the Supreme Court issued its final opinion and judgment in Menchaca, which clarified whether an insured can recover policy benefits based on an insurer’s violation of the Texas Insurance Code even though the jury failed to find that the insurer failed to comply with its obligations under the policy. On appeal, the Supreme Court held (1) State Farm’s first issue should be remanded for reconsideration in light of Menchaca; and (2) as to the remaining issues, the court of appeals’ judgment is affirmed. View "State Farm Lloyds v. Fuentes" on Justia Law

At issue was whether Grandparents were liable to Father for assisting in their daughter’s (Mother) interference with Father’s possessory rights to his children.Mother employed “egregious and outrageous tactics” to prevent Father from seeing the parties’ two children, including coaching the parties’ young son to falsely accuse his father of sexual abuse. While the abuse allegations were under investigation, Grandparents supported Mother by helping her care for the children. Father sued Grandparents for negligence, defamation, and “aiding and assisting” Mother’s interference with his possessory rights, in violation of Tex. Fam. Code chapter 42. The trial court awarded Father more than $10.5 million in damages. The court of appeals reversed as to the defamation charge and a small portion of the Family Code damages award but otherwise affirmed. The Supreme Court reversed in part and rendered a take-nothing judgment, holding (1) the defamation claims were unsustainable due to lack of pleadings and sufficient causation evidence; and (2) the evidence was legally insufficient to support Grandparents’ liability under chapter 42 and the tort theories alleged. View "Bos v. Smith" on Justia Law

Robin Goldsmith, a Louisiana resident, did not purposefully avail herself of the state of Texas such that Texas courts may exercise personal jurisdiction over her as to Old Republic National Title Insurance’s Company’s claim under the Texas Uniform Fraudulent Transfers Act.This dispute arose from a series of money transfers between Lisa Bell, a Texas resident, and Goldsmith in connection with the sale of Texas Property. Alleging that the transfers were fraudulent, Old Republic sued Bell and Goldsmith. In response to Old Republic’s suit, Goldsmith filed a special appearance objecting to the court’s jurisdiction over her. The trial court granted Goldsmith’s special appearance. The court of appeals affirmed. The Supreme Court affirmed, holding that Goldsmith’s contacts with the state of Texas were insufficient to confer specific or general jurisdiction over her with respect to Old Republic’s fraudulent transfer claim. View "Old Republic National Title Insurance Co. v. Bell" on Justia Law

The nature of the function a municipality was performing when it entered into a contract governs the analysis of whether the municipality was engaged in its governmental or proprietary function and thus whether the municipality was immune from suit.Plaintiff filed this suit alleging that the City of Jacksonville breached its lease agreements with Plaintiff. The City filed a motion for summary judgment arguing that governmental immunity barred the breach of contract claim. The trial court granted the motion. The court of appeals affirmed based on governmental immunity, concluding that the governmental/proprietary dichotomy that applies to tort claims does not apply to breach of contract claims. The Supreme Court reversed, holding that the dichotomy applies whether a municipality commits a tort or breaches a contract. On remand, the court of appeals held that governmental immunity applied to bar Plaintiff’s contract claim because the claim arose from the City’s performance of a governmental function. The Supreme Court reversed, holding that the contract claim arose from the City’s performance of a proprietary function so governmental immunity did not apply. View "Wasson Interests, Ltd. v. City of Jacksonville" on Justia Law

The one-satisfaction rule applied to this case, and therefore, the trial court erred in denying the nonsettling defendant settlement credits.At issue on this appeal was Plaintiff’s claims against nonsettling defendants alleging breach of contract, fraud, and other causes of action. Plaintiff had earlier settled with four other defendants. The jury returned a verdict in favor of Plaintiff. The nonsettling defendants asserted that, under the one-satisfaction rule, they were entitled to offset the final judgment by the amounts the four settling defendants paid to Plaintiff, plus interest. The trial court disagreed and rendered judgment against the nonsettling defendants, jointly and severally, for the full jury award. The court of appeals affirmed the trial court’s denial of settlement credits, ruling that Plaintiff’s claims against the nonsettling defendants were independent of the other injuries Plaintiff alleged against the settling defendants. The Supreme Court reversed, holding that the nonsettling defendants were entitled to reduce the judgment by the total amount of the settlements Plaintiff received and any applicable interest. View "Sky View At Las Palmas, LLC v. Mendez" on Justia Law

In this dispute over an offset provision in an oil and gas lease the Supreme Court reversed the judgment of the court of appeals reversing the trial court’s summary judgment in the lessee’s favor on the grounds that the lessee did not conclusively demonstrate compliance with the provision.On appeal, the court of appeals determined that the lessee did not conclusively prove that it complied with the offset provision and thus was not entitled to summary judgment. In reversing, the Supreme Court held (1) the offset provision contained specific requirements, and the lessee met those requirements; and (2) the court of appeals read a requirement into the lease that its unambiguous language did not support. View "Murphy Exploration & Production Co. v. Adams" on Justia Law

An individual qualifies as “unemployed” for purposes of the Texas Unemployment Compensation Act while taking unpaid leave from her job under the Family Medical Leave Act (FMLA), but eligibility for unemployment benefits requires more than “unemployed” status.Julia White went on FMLA leave for severe anxiety and depression. Before White returned to work for Wichita County, she filed a claim for unemployment benefits. The County contested the claim on the ground that White remained a County employee and thus did not qualify for benefits. The Texas Workforce Commission determined that White was “unemployed” while on her unpaid leave of absence and that it could pay her benefits if she met all other requirements. The trial court reversed. The court of appeals affirmed, concluding that it would be “absurd” for an individual to be entitled to unemployment benefits during FMLA leave. The Supreme Court reversed, holding (1) an individual on unpaid medical leave, even if protected under the FMLA, satisfies the Act’s definition of unemployed and may qualify for unemployment benefits if she meets the Act’s eligibility requirements; and (2) substantial evidence supported the Commission’s decision in this case. View "Texas Workforce Commission v. Wichita County" on Justia Law

The Parker County Appraisal District did not employ a facially unlawful means of appraising Taxpayers’ property, which appeared to derive much of its market value from saltwater disposal wells in which wastewater from oil and gas operations could be injected and permanently stored underground.When valuing for tax purposes Taxpayers’ tracts of land in Parker County, the Parker County Appraisal District assigned one appraised value to the wells and another appraised value to the land itself. Taxpayers argued before the trial court that the Tax Code did not permit the County to appraise the wells separately from the land itself where both interests are owned by the same person and have not been severed into discrete estates. The trial court granted summary judgment for Taxpayers. The court of appeals reversed. The Supreme Court affirmed, holding (1) there was nothing improper in the District’s decision to separately assigned and appraise the surface and the disposal wells, which were part of Taxpayers’ real property and contributed to its value; and (2) the Tax Code does not prohibit the use of different appraisal methods for different components of a property. View "Bosque Disposal Systems, LLC v. Parker County Appraisal District" on Justia Law