Justia Texas Supreme Court Opinion Summaries

Except in rare circumstances, when the admissibility of a video is at issue, the proper exercise of discretion requires the trial court to actually view the video evidence before ruling on its admissibility.The trial court in this personal-injury suit arising from a workplace accident excluded video evidence without watching it. The video was taken by an investigator hired by the employer and recorded the employee engaging in physical activities over the course of two days. The employer sought to admit the surveillance video into evidence to support its defensive theory that the employee was overstating his pain and downplaying his ability to return to some form of work. Because the surveillance video was highly probative in this case, the Supreme Court reversed the judgment entered in favor of the employee awarding him nearly $10 million, holding that the video should not have been excluded under Tex. R. Evid. 403, and the trial court’s abuse of discretion was harmful. View "Diamond Offshore Services Ltd. v. Williams" on Justia Law

Galveston County failed to rebut the presumed constitutionality of a statutory formula determining the taxable value of leased natural-gas compressors located in its jurisdiction. Further, Washington County was the taxable situs for the compressors.The Supreme Court reversed the judgment of the Court of Appeals, which held that the parties failed to produce summary judgment evidence demonstrating, as a matter of law, that the statutory formula was either a reasonable or an unreasonable method of calculating the compressors’ reasonable market value. The court of appeals also held that Galveston County was the taxable situs of the compressors. The Supreme Court held (1) the court of appeals erred by not rendering judgment that the County failed to rebut the presumed constitutionality of the valuation statutes; and (2) the legislature’s statutory taxation scheme sets situs in the county where the dealer does business, and therefore, Washington County was the proper taxable situs for the compressors. View "EXLP Leasing, LLC v. Galveston Central Appraisal District" on Justia Law

A defendant can prevail on the merits of its counterclaims against a governmental entity when the governmental entity recovers monetary relief on its affirmative claims by filing a lien and a lis pendens and then nonsuits its affirmative claims where the defendant seeks an offset against the amount the governmental entity recovered through the litigation process.Petitioner, which operated pecan orchards, entered into water-supply agreements with Respondent, a political subdivision. Respondent sued Petitioner for breach of contract. Petitioner counterclaimed for breach of contract and fraud. After Respondent recorded a crop lien and a lis pendens against Petitioner’s orchards, Petitioner paid Respondent the amount it sought to remove the lien and lis pendens but continued to pursue its counterclaims seeking an offset against that payment. Respondent later nonsuited its claims. The trial court granted summary judgment for Respondent, ordering that Petitioner take nothing on its counterclaims. The court of appeals affirmed. The Supreme Court reversed, holding that the court of appeals erred in concluding that Petitioner could not prevail on the merits of its counterclaims merely because Respondent obtained its recovery by filing a lien and lis pendens. View "C. Borunda Holdings, Inc. v. Lake Proctor Irrigation Authority of Comanche County" on Justia Law

A defendant can prevail on the merits of its counterclaims against a governmental entity when the governmental entity recovers monetary relief on its affirmative claims by filing a lien and a lis pendens and then nonsuits its affirmative claims where the defendant seeks an offset against the amount the governmental entity recovered through the litigation process.Petitioner, which operated pecan orchards, entered into water-supply agreements with Respondent, a political subdivision. Respondent sued Petitioner for breach of contract. Petitioner counterclaimed for breach of contract and fraud. After Respondent recorded a crop lien and a lis pendens against Petitioner’s orchards, Petitioner paid Respondent the amount it sought to remove the lien and lis pendens but continued to pursue its counterclaims seeking an offset against that payment. Respondent later nonsuited its claims. The trial court granted summary judgment for Respondent, ordering that Petitioner take nothing on its counterclaims. The court of appeals affirmed. The Supreme Court reversed, holding that the court of appeals erred in concluding that Petitioner could not prevail on the merits of its counterclaims merely because Respondent obtained its recovery by filing a lien and lis pendens. View "C. Borunda Holdings, Inc. v. Lake Proctor Irrigation Authority of Comanche County" on Justia Law

The mother of an adult disabled child had standing under the Texas Family Code to seek child support even though the child did not live with the mother, the mother did not have physical custody of the child, and the mother was not the child’s legal guardian.The trial court directed the father of the disabled child to pay child support to the mother, concluding that both the father and the mother, as parents, had a duty to support the child and that it was in the child’s best interest that they do so. The court of appeals reversed, concluding that the mother did not have standing. The Supreme Court reversed the judgment of the court of appeals and remanded to that court for it to consider the issues it did not reach, holding that, under Tex. Fam. Code 154.303(a)(1), the mother had standing to seek support in this case. View "In re Interest of C.J.N.-S." on Justia Law

The mother of an adult disabled child had standing under the Texas Family Code to seek child support even though the child did not live with the mother, the mother did not have physical custody of the child, and the mother was not the child’s legal guardian.The trial court directed the father of the disabled child to pay child support to the mother, concluding that both the father and the mother, as parents, had a duty to support the child and that it was in the child’s best interest that they do so. The court of appeals reversed, concluding that the mother did not have standing. The Supreme Court reversed the judgment of the court of appeals and remanded to that court for it to consider the issues it did not reach, holding that, under Tex. Fam. Code 154.303(a)(1), the mother had standing to seek support in this case. View "In re Interest of C.J.N.-S." on Justia Law

Defendants’ failure to fully comply with a temporary restraining order did not justify sanctions even more severe than death-penalty sanctions imposed by the trial court.Plaintiffs sought a temporary restraining order (TRO) against Defendants. Without taking evidence, the court signed a TRO prohibiting Defendants from engaging in certain conduct. Plaintiffs later filed a motion for contempt and sanctions, alleging that Defendants knowingly violated the TRO. The trial court granted the motion in an order stating that “death penalty sanctions should be imposed” against Defendants. The court then awarded sanctions of $897,938. The court of appeals affirmed. The Supreme Court reversed and remanded the case, holding (1) Defendants knowingly violated the TRO without a compelling excuse; but (2) the extreme sanction imposed for the violations of the TRO was an abuse of discretion. View "Altesse Healthcare Solutions, Inc. v. Wilson" on Justia Law

A turnover order is not a final, appealable judgment when it merely orders funds subject to an as yet unadjudicated ownership dispute into the court’s registry.Here, a turnover order directed funds subject to disputed ownership claims into the court’s registry “without prejudice” to the rights of either the judgment creditor or non-judgment debtor to later seek the funds’ release. Nearly six months after the trial court signed the turnover order, Respondent filed a motion to enforce the turnover order and to have the registry funds released to it on the grounds that Petitioner triggered a condition for releasing the funds when it neglected to appeal the turnover order. The trial court ordered the turnover order enforced and registry funds released to Respondent (the “release order”). The court of appeals dismissed Petitioner’s appeal for want of jurisdiction due to Petitioner’s failure to timely appeal the turnover order. The Supreme Court reversed, holding (1) Petitioner timely appealed the release order; and (2) the turnover order’s provisions did not function as a mandatory injunction, which meant the release order was the final judgment on Petitioner’s claims. View "Alexander Dubs Jefferson & Townsend LLP v. Chevron Phillips Chemical Co." on Justia Law

In this case involving an arbitration provision in short-term loan contracts the Supreme Court affirmed the judgment of the court of appeals ruling (1) the borrowers’ claims against the lender came within the arbitration provision, and (2) the lender did not waive its right to arbitrate by providing information to the district attorney that checks written to the lender by the borrowers had been returned for insufficient funds.The borrowers sued the lender, claiming that the lender wrongfully used the criminal justice system to collect unpaid loans by filing false charges against them. The lender responded by filing a motion to compel arbitration. The trial court denied the motion, concluding that the arbitration clause was inapplicable because the borrowers' claims related solely to the lender’s illegal use of the criminal justice system and that the lender waived its right to arbitration by substantially invoking the judicial process. The court of appeals reversed. The Supreme Court affirmed, holding (1) the borrowers’ claims were within the scope of the arbitration provision; and (2) the lender did not substantially invoke the judicial process, and therefore, there was no evidence to support the trial court’s finding the the lender waived its right to arbitrate. View "Henry v. Cash Biz, LP" on Justia Law

In this case involving an arbitration provision in short-term loan contracts the Supreme Court affirmed the judgment of the court of appeals ruling (1) the borrowers’ claims against the lender came within the arbitration provision, and (2) the lender did not waive its right to arbitrate by providing information to the district attorney that checks written to the lender by the borrowers had been returned for insufficient funds.The borrowers sued the lender, claiming that the lender wrongfully used the criminal justice system to collect unpaid loans by filing false charges against them. The lender responded by filing a motion to compel arbitration. The trial court denied the motion, concluding that the arbitration clause was inapplicable because the borrowers' claims related solely to the lender’s illegal use of the criminal justice system and that the lender waived its right to arbitration by substantially invoking the judicial process. The court of appeals reversed. The Supreme Court affirmed, holding (1) the borrowers’ claims were within the scope of the arbitration provision; and (2) the lender did not substantially invoke the judicial process, and therefore, there was no evidence to support the trial court’s finding the the lender waived its right to arbitrate. View "Henry v. Cash Biz, LP" on Justia Law