Justia Texas Supreme Court Opinion Summaries

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

In this law firm’s quantum-merit suit for the reasonable value of its services in assisting its client reach a comprehensive settlement of various lawsuits filed against him, the Supreme Court held (1) despite an unenforceable oral contingent-fee agreement, the statute of frauds did not preclude the firm’s quantum-merit claim for services it performed under the agreement; and (2) there was sufficient evidence to demonstrate that the firm performed compensable services in negotiating the global settlement, but the firm’s damages expert’s opinion as to the reasonable value of the firm’s services could not be given legal weight, and without the opinion, there was legally insufficient evidence to support the jury’s award. Where there was some evidence of the reasonable value of the law firm’s services, the Supreme Court reversed the part of the court of appeals’ judgment that reinstated the jury’s award, which the trial court set aside in favor of a take-nothing judgment, and remanded the case to the trial court for a new trial on the amount of the firm’s recovery. View "Hill v. Shamoun & Norman, LLP" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals in this case requiring interpretation of retained-acreage provisions in oil-and-gas lease instruments, holding that acreage “included within the proration unit for each well…prescribed by field rules” refers to acreage set by the field rules, not acreage assigned by the operator.XOG Operating, LLC conveyed to Chesapeake Exploration Limited Partnership and Chesapeake Exploration, LLC (collectively, Chesapeake) its rights as lessee under four oil-and-gas leases in three sections of land. Under a retained-acreage provision, the assigned interest would revert to XOG after the primary term. As relevant to appeal, Chesapeake would retain for each well drilled the acreage “included within the proration…unit” “prescribed by field rules.” The acreage not retained by Chesapeake would revert to XOG on termination of the assignment. Chesapeake completed six wells during the primary term of the assignment, five of which were located in an area for which the Railroad Commission had promulgated field rules. The sixth well was located in an area for which there were no field rules. In Chesapeake’s view, it retained all of the assigned acreage. XOG sued Chesapeake to construe the retained-acreage provision. The Supreme Court affirmed the trial court's decision that the none of the land at issue reverted to XOG under the retained-acreage provision. View "XOG Operating, LLC v. Chesapeake Exploration Limited Partnership" on Justia Law

In this case involving competing claims to mineral-lease interests in two tracts of land, the Supreme Court affirmed the judgments of the trial court and court of appeals that the acreage Endeavor Energy Resources, LP and Endeavor Petroleum, LLC (collectively, Endeavor) retained under “retained-acreage clauses” in expired leases did not include the two tracts at issue.Discovery Operating, Inc., which drilled producing wells on the two subject tracts, claimed the mineral-lease interests based on leases acquired directly from the mineral-estate owners. Endeavor based its claim on prior leases with the same owners covering land that included the two subject tracts. Endeavor never drilled on the tracts, and Endeavor’s leases’ terms had expired. However, the leases included “retained-acreage clauses” providing that the leases would continue after they expired as to a certain number of acres associated with each of the wells Endeavor drilled on adjacent tracts. Supreme Court affirmed the judgment of the lower courts, holding that “a governmental proration unit assigned to a well” refers to acreage assigned by the operator, not by field rules. View "Endeavor Energy Resources, LP v. Discovery Operating, Inc." on Justia Law

The Supreme Court withdrew its judgment and opinion issued in this case on April 7, 2017 and, while it reaffirmed the legal principles and rules announced in that opinion, it disagreed as to the procedural effect of those principles in this case. Its disposition remained the same, however, because a majority of the Court agreed to reverse the judgment of the court of appeals and remand the case to the trial court for a new trial.The primary issue in this case was whether Insured could recover policy benefits based on Insurer’s violation of the Texas Insurance Code even where the jury failed to find that Insurer failed to comply with its obligations under the policy. Here, the Court (1) unanimously reaffirmed the five rules it announced in the first opinion addressing the relationship between contract claims under an insurance policy and tort claims under the Insurance Code; (2) reaffirmed the holding in the first opinion that the trial court erred by disregarding the jury’s answer to a jury question; and (3) addressed the procedural effect of the Court’s holdings in this case but reached three different conclusions. The Court then remanded this case for a new trial. View "USAA Texas Lloyds Co. v. Menchaca" on Justia Law

In this billing dispute between a general contractor, Dudley Construction, Ltd., and a pipe supplier, ACT Pipe and Supply, Inc., the Supreme Court affirmed the judgment of the court of appeals in part and reversed it in part, holding (1) in defending a favorable judgment notwithstanding the jury’s verdict, ACT successfully raised a “cross-point” in the court of appeals that preserved an alternative argument proscribing the jury’s original verdict, even though ACT did not formally label its argument a “cross-point”; and (2) attorney’s fees are not recoverable for a claim brought under the Texas Construction Trust Fund Act. The Court remanded this case to the trial court for further proceedings. View "Dudley Construction, Ltd. v. ACT Pipe & Supply, Inc." on Justia Law

At issue in this appeal was whether the Alamo Heights Independent School District was immune from Employee’s suit alleging Texas Commission on Human Rights Act (TCHRA) claims.The Supreme Court reversed the judgment of the court of appeals and rendered judgment dismissing Employee’s TCHRA claims in which she alleged same-sex harassment and bullying by female coaches in the girls athletic department at a San Antonio middle school. The Court held (1) the record bore no evidence that the inappropriate conduct alleged was gender motivated, and therefore, the evidence did not raise an inference of gender-motivated discrimination; (2) Employee did not produce evidence to support her retaliation claim when no presumption of unlawful retaliation existed under the McDonnell Douglas burden-shifting framework; and (3) governmental immunity was not waived in this case, and subject-matter jurisdiction was lacking. View "Alamo Heights Independent School District v. Clark" on Justia Law