Justia Texas Supreme Court Opinion Summaries

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

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

In this personal injury case, the Supreme Court reversed the judgment of the court of appeals reversing the trial court’s grant of summary judgment in favor of Defendant based on limitations, holding that the court of appeals erred in applying the discovery rule.Plaintiff was injured when he was exposed to and burned by caustic chemicals while working at an oil well site. Less than two years later, Plaintiff sued several defendants. Plaintiff joined Defendant more than two years after he was injured but less than two years after he was diagnosed with cancer, which he attributed to the chemical exposure. Plaintiff argued that he sued Defendant in a timely manner because his cancer was inherently undiscoverable and that his cause of action did not accrue until he discovered the cancer. The court of appeals reversed the summary judgment for Defendant, concluding that Plaintiff raised a genuine issue of material fact about whether he knew or should have known the nature of his injury before his cancer diagnosis. The Supreme Court reversed, holding that the court of appeals incorrectly applied the discovery rule and the latent occupational disease rule. View "Schlumberger Technology Corp. v. Pasko" on Justia Law

The Supreme Court denied the petition for writ of mandamus filed by Paul Elizondo, Cynthia Elizondo, and Eagle Fabricators, Inc. (collectively, Elizondo) directing the court of appeals to vacate its opinion directing the trial court to vacate an amended order omitting a Lehmann-like finality phase that it had included in its original order after its plenary power had expired. See Lehmann v. Har-Con Corp., 39 S.W.3d 191, 205-06 (Tex. 2001).In this action, Elizondo argued that the original order of the trial court was not final and, in the alternative, that Lehmann did not apply to the trial court’s original order. The Supreme Court held (1) the original order’s finality phase was clear, unequivocal, and neither ambiguous nor absurd, and the court of appeals correctly reasoned that the finality phase rendered the record irrelevant to determining whether the order was final; and (2) the trial court’s amended order attempting to correct judicial error beyond the period of that court’s plenary power was void. View "In re Paul & Cynthia Elizondo" on Justia Law

The Texas Whistleblower Act (WBA) does not apply to open-enrollment charter schools operated by a tax-exempt entity.Petitioner operated an open-enrollment charter school that provided tuition-free public education to students on multiple campuses. Respondent, a teacher for the school, sued the school for violating the WBA by retaliating against her. The trial court denied the school’s plea to the jurisdiction asserting immunity from suit. The court of appeals affirmed. The Supreme Court reversed, holding that because the WBA contains no specific statement that it applies to open-enrollment charter schools, see section 12.1058(c) of the Texas Charter Schools Act, it does not apply to open-enrollment charter schools. View "Neighborhood Centers Inc. v. Walker" on Justia Law

In this dispute governed by a collective bargaining agreement between a county and its deputy constables, the Supreme Court affirmed the judgment of the court of appeals ruling that deputy constables are “police officers” entitled to enter into collective bargaining agreements (CBAs) with their public employers under Tex. Loc. Gov’t Code Ann. 174 and that the arbitrator did not exceed his authority in awarding relief to the deputy constables.The county petitioned to vacate the arbitrator’s award, arguing that the arbitrator exceeded his authority in concluding that the county violated the CBA by eliminating several deputy constable positions without regard to seniority and ordering the county to reinstate the deputies in order of seniority. The trial court granted the county’s motion for summary judgment and rendered final judgment in its favor. The court of appeals reversed. The Supreme Court affirmed, holding that deputy constables are “police officers” under the CBA, that the CBA was valid and enforceable, and that the arbitrator did not exceed his authority in ordering the deputies’ reinstatement on a seniority basis. View "Jefferson County v. Jefferson County Constables Ass’n" on Justia Law

The Supreme Court reversed the judgment of the court of appeals in this negligence case arising from a motor-vehicle accident that occurred while a drilling-company employee was driving his coworkers from a drilling site to employer-provided housing after a shift, holding that the employer was not entitled to summary judgment on the injured employee’s (Plaintiff) vicarious-liability claim.Plaintiff filed suit against Employer, alleging that Employer was vicariously liable for the driver’s negligence. The trial court granted summary judgment for Employer, and the court of appeals affirmed. The Supreme Court reversed, holding that Employer was not entitled to summary judgment on either no-evidence or traditional grounds on Plaintiff’s vicarious-liability claim. View "Painter v. Amerimex Drilling I, Ltd." on Justia Law