Justia Texas Supreme Court Opinion Summaries

The Texas Citizens Participation Act (TCPA) applied to tort claims brought by a nonclient against an attorney based in part on statements the attorney made in open court on behalf of his client, and the attorney was entitled to dismissal under the TCPA.The trial court denied Defendant-attorney’s motion to dismiss. The court of appeals affirmed, ruling that the TCPA applied to the claims against Defendant, Plaintiff made a prima facie case for each element of his claims, and Defendant failed to prove his attorney-immunity defense. The Supreme Court reversed, holding (1) the TCPA applies to protect an attorney’s in-court statements on behalf of his client during a judicial proceeding; and (2) assuming without deciding that Plaintiff carried his burden to make a prima facie case as to the elements of his claims against Defendant, Defendant was nevertheless entitled to dismissal under the affirmative defense of attorney immunity. View "Youngkin v. Hines" on Justia Law

At issue was a trial court order requiring Defendant-hospital to produce information regarding its reimbursement rates from private insurers and public payers for the services it provided to Plaintiff.Plaintiff sought a declaratory judgment that Defendant’s charges were unreasonable and its hospital lien for the amount of its services was invalid to the extent it exceeded a reasonable and regular rate for services rendered. During discovery, the trial court ordered Defendant to produce information regarding the reimbursement rates at issue. Defendant filed a petition for writ of mandamus arguing that the trial court abused its discretion in ordering production of the information because the reimbursement rates were irrelevant to whether its charges to Plaintiff, who was uninsured, were reasonable. The Supreme Court denied the writ, holding that the amounts Defendant accepted as payment for services from other patients, including those covered by private insurance and government benefits, were relevant to whether the charges to Plaintiff were reasonable and were thus discoverable. View "In re North Cypress Medical Center Operating Co." on Justia Law

At issue was the function of a clause in a real property deed that “saves and excepts” one-half of “all royalties from the production of oil, gas and/or other minerals that may be produced from the above described premises which are now owned by Grantor” when the deed does not disclose that the grantor does not own all of the royalty interests and does not except any other royalty interests from the conveyance.The trial court held that the deeds did not create a Duhig problem - where the grantor owns less than he purports to convey - by construing the clause as reserving for the grantor one-half of all royalties “which [were then] owned by Grantor.” The court of appeals determined that the clause created a Duhig problem, interpreting the clause as reserving for the grantor one-half of all royalties produced from the “above described premises which [were then] owned by Grantor.” The Supreme Court affirmed as modified, holding (1) instead of reserving a one-half royalty interest for the grantors, the clause merely excepted that interest from the grant, and therefore, the deeds did not create a Duhig problem; and (2) each party with an interest in the tracts owned a one-quarter interest in the royalties produced. View "Perryman v. Spartan Texas Six Capital Partners, Ltd." on Justia Law

A trial court’s authority to distinguish between genuine and non-genuine fact issues includes the authority to apply the so-called “sham affidavit rule” when confronted with evidence that appears to be a sham designed to avoid summary judgment.Under the sham affidavit rule, if a party submits an affidavit that conflicts with the affiant’s prior sworn testimony and does not provide a sufficient explanation for the conflict, a trial court may disregard the affidavit when deciding whether the party has raised a genuine fact issue to avoid summary judgment. In this commercial dispute, the trial court struck an affidavit as a sham under the rule and granted partial summary judgment. A divided panel of the court of appeals affirmed and adopted the sham affidavit doctrine, which had not previously been explicitly recognized by the court of appeals. The Supreme Court affirmed the court of appeals’ decision as to the partial summary judgment grant, as the trial court properly concluded that the affidavit in question did not raise a genuine fact issue sufficient to survive summary judgment. The Court then remanded to the court of appeals to consider whether any claims remained unresolved. View "Lujan v. Navistar, Inc." on Justia Law

In this property-tax dispute regarding ownership of tangible personal property, the Supreme Court held (1) when, as in this case, an ownership correction to an appraisal roll does not increase the amount of property taxes owed for subject property in the year of the correction, an appraisal district’s chief appraiser has statutory authority under Tex. Code Ann. Prop. 25.25(b) to make such a correction even when the correction necessarily alters the taxing units’ expectation of who is liable for payment of property taxes; (2) an agreement under Tex. Code Ann. Prop. 1.111(e) may be rendered voidable if it is proven that it was induced by fraud; and (3) a purported owner challenging ownership on the appraisal roll is not entitled to attorney’s fees under Tex. Code Ann. Prop. 42.29. Accordingly, the Court reversed the judgment of the court of appeals ruling that Willacy County Appraisal District lacked authority to change a property ownership determination under section 25.25(b), without reaching the issue of whether a section 1.111(e) agreement may be voided if it was induced by fraud, and remanding the case for a determination of attorney’s fees consistent with section 42.29. The Supreme Court remanded the case to the court of appeals for further proceedings. View "Willacy County Appraisal District v. Sebastian Cotton & Grain, Ltd." on Justia Law

At issue in this statutory-construction case was the damages-cap and election-of-remedies provisions of the Texas Tort Claims Act (TTCA) with respect to independent contractors performing essential governmental functions.Plaintiff, the daughter of a pedestrian who was struck and killed by a public bus in Fort Worth, brought claims under the TTCA against the Fort Worth Transportation Authority (FWTA), its two independent contractors, and the bus driver. The Supreme Court held (1) the TTCA’s damages cap applies cumulatively when, as in this case, an independent contractor performed essential governmental functions of a transportation authority; (2) the TTCA’s election-of-remedies provision extends to cover an employee of an independent contractor performing essential governmental functions; and (3) the transit defendants in this case were not entitled to attorney’s fees arising out of interpleader. Accordingly, the Supreme Court reversed the court of appeals’ judgment and reinstated the trial court’s judgment in favor of FWTA with respect to issues one and two, and affirmed the denial of attorney’s fees and remand to the trial court for further proceedings. View "Fort Worth Transportation Authority v. Rodriguez" on Justia Law

The court of appeals properly vacated the temporary injunctions granted by the district court forestalling the Commissioner of Education’s revocation of two open-enrollment charter schools’ charters and dismissed the schools’ suit seeking judicial review of the Commissioner’s revocation on the grounds that sovereign immunity barred the schools’ claims.In their petitions for judicial review, the two open-enrollment schools challenged the validity of the Commissioner’s decision to revoke their respective charters, raising both constitutional and ultra vires complaints. The district court issued two orders temporarily enjoining the Commissioner from proceeding with the revocations. The court of appeals vacated the temporary injunctions and dismissed the schools’ underlying claims, concluding that all claims were barred by sovereign immunity. The Supreme Court affirmed, holding that the enabling statutes precluded judicial review of the Commissioner’s executive decisions at issue here, and no basis otherwise existed to invoke the district court’s inherent authority. View "Honors Academy, Inc. v. Texas Education Agency" on Justia Law

The Texas Public Utility Regulatory Act grants the Texas Public Utility Commission (the PUC) exclusive jurisdiction to resolve issues underlying a customer’s claim that a PUC-regulated utility breached a contract by failing timely to provide electricity.Chaparral Energy LLC filed a breach of contract action against Oncor Electric Delivery Company, LLC, a PUC-regulated utility. A jury found in favor of Chaparral. While Oncor’s appeal was pending, the Fort Worth Court of Appeals issued its decision in Oncor Electric Delivery Co. v. Giovanni Homes Corp., 438 S.W.3d 644 (Tex.App. 2014), which held that the PUC had exclusive jurisdiction over Giovanni Homes’s breach of contract claim against Oncor. Oncor then moved to dismiss Chaparral’s claim for want of jurisdiction. The court of appeals affirmed. The Supreme Court reversed and rendered judgment dismissing the case for want of jurisdiction, holding (1) Chaparral was required to exhaust its administrative remedies before the PUC before seeking relief in district court; (2) the inadequate-remedy exception to the exhaustion-of-remedies requirement does not apply in this case; and (3) requiring Chaparral to exhaust administrative remedies does not deprive it of its constitutional rights to a jury trial and to open courts. View "Oncor Electric Delivery Co. LLC v. Chaparral Energy, LLC" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the trial court’s denial of Defendant’s motion to dismiss the defamation claim filed against him, holding that, contrary to the conclusion of the court of appeals, Defendant’s allegedly defamatory communications did relate to a “matter of public concern” as defined by the Texas Citizens Participation Act (TCPA).Defendant moved to dismiss the defamation claim against him, arguing that Plaintiff could not establish a prima facie case to survive dismissal under the TCPA. The trial court did not rule on the motion to dismiss the defamation claim within the statutory period, so it was denied by operation of law. The court of appeals affirmed, holding that the challenged communications did not related to a “matter of public concern.” The Supreme Court reversed, holding (1) Defendant satisfied his initial burden to establish the applicability of the TCPA under Tex. Civ. Prac. & Rem. Code 27.005(b); and (2) therefore, the matter must be remanded for the court of appeals to decide whether Plaintiff established a prima facie case for each essential element of its defamation claim or whether Plaintiff established a valid defense. View "Adams v. Starside Custom Builders, LLC" on Justia Law

The Supreme Court conditionally granted Plaintiff mandamus relief from trial court discovery sanctions in this personal injury case arising from a traffic accident.The trial court judge in Jim Wells County, where the case was pending, denied Plaintiff’s motion for protective orders regarding discovery sought from some of her medical providers. The custodians of the medical providers’ records were located in Bear County and were not parties to the lawsuit. After the Bear County district court judge issued his order granting the custodians protective orders, the Jim Wells County district court judge granted Defendants’ motion to exclude and ordered that certain testimony, medical records, and charges be excluded from the trial as sanctions. Plaintiff sought mandamus relief. The Supreme Court conditionally granted relief, holding that the requirements for mandamus to issue were satisfied. View "In re Carolina Garza" on Justia Law