Justia Texas Supreme Court Opinion Summaries

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

The Supreme Court affirmed the judgment of the court of appeals reversing the trial court’s ruling that TRO-X, LP was entitled to a back-in percentage of the working interest in five mineral leases under which Anadarko Petroleum was lessee.TRO-X sued Anadarko, asserting claims for breach of contract and trespass to try title and seeking a declaratory judgment that the leases were top leases and therefore subject to TRO-X’s back-in interest. The trial court concluded that the leases were top leases, in which TRO-X retained a back-in interest, rather than new leases, which washed out TRO-X’s interest. In reversing, the court of appeals concluded that the leases were not top leases. The Supreme Court agreed, holding that the leases at issue were not top leases subject to TRO-X’s back-in interest. View "TRO-X, L.P. v. Anadarko Petroleum Corp." on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the trial court’s decision that a homeowner violated certain restrictive covenants that limit tracts to residential purposes and single-family residents by operating a business on a residential tract and engaging in multi-family, short-term vacation rentals.The court of appeals concluded that the rental agreements contracted the residential-purpose limitation because the renters’ stays were merely temporary. The Supreme Court reversed, holding (1) the unambiguous restrictive covenants did not restrict the homeowner from renting his single-family residence to occupants to use his home for a “residential purpose,” no matter how short-lived; and (2) therefore, the homeowner did not violate the restrictive covenants by entering into short-term vacation rental agreements. View "Tarr v. Timberwood Park Owners Ass’n, Inc." on Justia Law

At issue in this healthcare-liability case was whether the jury was properly allowed to consider, in deciding negligence, what a physician (Defendant) did or did not tell his patient (Plaintiff) about an inexperienced resident’s involvement in performing Plaintiff’s surgery, even though Plaintiff did not seek recovery on that basis.A jury found Defendant’s negligence caused Plaintiff’s injuries. The court of appeals reversed and remanded the case for a new trial, holding (1) the trial court’s refusal to instruct the jury not to consider Defendant’s failure to disclose the resident’s level of involvement was error, and the error was not harmless; and (2) Plaintiff’s expert was “practicing medicine” at the time of trial and thus qualified to testify. The Supreme Court affirmed, holding that the court of appeals correctly found that the charge error required a new trial. View "Benge v. Williams" on Justia Law

In this libel-by-implication case, a column written by Steve Blow and published by The Dallas Morning News (collectively, Petitioners) was reasonably capable of meaning that John and Mary Ann Tatum acted deceptively and that the accusation of deception was reasonably capable of defaming the Tatums. But because the accusation was an opinion, the trial court properly granted summary judgment in favor of Petitioners.The Tatum filed suit alleging libel and libel per se against Petitioners alleging that the column at issue defamed them. The trial court granted summary judgment for Petitioners. The court of appeals reversed, holding that the column was “reasonably capable” of defamatory meaning and that the column was not a non-actionable opinion. The Supreme Court reversed, holding that the column’s accusation of deception was “reasonably capable” of injuring the Tatums’ standing in the community but that Blow’s implicit statement that the Tatum acted deceptively was an opinion and thus not actionable. View "Dallas Morning News, Inc. v. Tatum" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the trial court’s grant of Respondent’s petition seeking expungement for the records and files relating to the charge for which Respondent was acquitted.Respondent was arrested for two unrelated charges. Respondent pleaded guilty to one charge and was acquitted of the other. Following her acquittal, Respondent filed a petition pursuant to Tex. Code Crim. Proc. 55.01 seeking expungement of the records and files relating to the charge for which she was acquitted. In opposing the petition, the State argued that Respondent did not meet the statutory requirements because her arrest resulted in both an acquittal and a conviction. The trial court granted the petition. The court of appeals affirmed. The Supreme Court affirmed, holding (1) section 55.01(a)(1) is neither entirely arrest-based nor offense-based; and (2) partial redactions and expunctions of records are valid remedial actions. View "State v. T.S.N." on Justia Law

Harris County, the employer of deputy constable Kenneth Caplan, was entitled to governmental immunity on Plaintiff’s claim that the County used tangible personal property when Caplan shot Plaintiff.Caplan was off duty and used his personal firearm when he struck and injured Plaintiff. Attempting to trigger the Tort Claims Act’s limited waiver of governmental immunity, Plaintiff alleged that the County’s use of tangible personal property caused the injuries she suffered when Caplan shot her. The trial court granted the County’s plea to the jurisdiction and dismissed the case. The court of appeals found that Plaintiff failed to establish a waiver of the County’s immunity but remanded the case to allow Plaintiff to replied and conduct more discovery. The Supreme Court affirmed in part, reversed in part, and rendered judgment for the County, holding that Plaintiff’s allegations failed to trigger the Texas Tort Claims Act’s waiver of the County’s governmental immunity, and neither further discovery nor repleading could cure this defect. View "Harris County, Texas v. Annab" on Justia Law