Justia Texas Supreme Court Opinion Summaries

Christine John and Christopher Lewis were injured in a rear-end collision involving a tractor-trailer driven by Roberto Alonzo. In the subsequent personal-injury lawsuit, Alonzo and his employer, New Prime, Inc., admitted liability for Alonzo’s negligence, leaving damages as the only issue at trial. The jury awarded $12 million to John and $450,000 to Lewis for physical pain and mental anguish. Alonzo and New Prime sought a new trial, arguing that the plaintiffs’ counsel had inflamed the jury with an unprovoked accusation of race and gender bias. The trial court rejected this motion, and the court of appeals affirmed the judgment.The Supreme Court of Texas reversed the lower courts' decisions, finding that the plaintiffs’ counsel had indeed crossed the line with an uninvited accusation of discriminatory animus. The court noted that while it is not inherently improper to question potential jurors about bias, the plaintiffs’ counsel had gone further by accusing the defense of seeking a lower damages amount because John is a black woman. The court found this argument to be inflammatory, uninvited, and unprovoked, and it concluded that it was so prejudicial that its harmfulness was incurable. The court therefore reversed the judgment and remanded the case for a new trial. View "Alonzo v. Lewis" on Justia Law

A mother sued her doctor and his medical practice for allegedly failing to perform a sterilization procedure she paid for and then failing to tell her that the procedure was not performed. She claims the doctor’s actions caused an unplanned pregnancy and the birth of her healthy fourth child. The mother sought to recover damages for medical expenses, physical pain and suffering, mental anguish, and the costs to maintain, support, and educate her daughter.The trial court granted summary judgment for the doctor as to all claims, and the mother timely appealed. A divided court of appeals reversed in part and remanded to the trial court for further proceedings. The majority affirmed the grant of summary judgment as to most of the mother’s claims, reasoning that they were impermissibly recast health care liability claims. But the majority reversed the grant of summary judgment as to the medical-negligence claim, holding that the mother had produced some evidence of duty, breach, and damages.The Supreme Court of Texas held that when a mother alleges that medical negligence proximately caused an unplanned pregnancy, that claim is not foreclosed merely because the ultimate result is the birth of a healthy child. But the recoverable damages are limited. The mother may recover the cost of the sterilization procedure and economic damages designed to compensate for injuries proximately caused by the negligence, such as medical expenses incurred during the pregnancy, delivery, and postnatal period, if proven. But Texas law does not permit recovery of the expenses of raising the healthy child, or any noneconomic damages, because the birth and life of a healthy child do not constitute an injury under Texas law. The court reversed the court of appeals’ judgment in part and reinstated the trial court’s judgment. View "Noe v. Velasco" on Justia Law

The case involves two plaintiffs, Michael Grim and Jim Maynard, who were employees of the Denton Municipal Electric (DME), a local electric utility owned by the City of Denton. The plaintiffs supported the construction of a controversial new power plant, the Denton Energy Center (DEC). Keely Briggs, a member of the Denton city council, opposed the new plant and leaked internal city documents about the project to a local newspaper. The plaintiffs reported Briggs's leak of confidential vendor information, alleging it violated the Public Information Act and the Open Meetings Act. They claimed that this report triggered the protections of the Whistleblower Act. The plaintiffs were later fired, which they alleged was retaliation for their report about Briggs.The case was initially heard in the district court, where the city argued that the Whistleblower Act did not apply because the plaintiffs did not report a violation of law "by the employing governmental entity or another public employee." The court was not convinced, and the case proceeded to a jury trial, which resulted in a $4 million judgment for the plaintiffs. The city appealed, raising several issues, including the legal question of whether the Whistleblower Act applied in this case. The court of appeals affirmed the district court's decision.The Supreme Court of Texas reversed the judgment of the court of appeals. The court held that the Whistleblower Act did not protect the plaintiffs because they reported a violation of law by a lone city council member, not by the employing governmental entity or another public employee. The court found that the lone city council member lacked any authority to act on behalf of the city, and her actions could not be imputed to the city. Therefore, her violation of law was not a "violation of law by the employing governmental entity." The court concluded that the plaintiffs did not allege a viable claim under the Whistleblower Act, and rendered judgment for the city. View "CITY OF DENTON v. GRIM" on Justia Law

The case revolves around a construction dispute where several homeowners in the San Marcial neighborhood sued Oscar Renda Contracting, Inc., for negligence and gross negligence. The homeowners alleged that the company's misuse of heavy equipment and faulty construction techniques caused damage to their homes during the construction of a drainage pipeline. They sought actual damages to restore their properties and exemplary damages based on gross negligence.The trial court found Renda Contracting negligent and grossly negligent. However, the jury was not unanimous in deciding the amount of exemplary damages, with ten out of twelve jurors agreeing. Consequently, the trial court omitted exemplary damages from the judgment. The homeowners appealed, and the court of appeals reversed the decision, arguing that unanimity as to exemplary damages could be implied despite a divided verdict.The Supreme Court of Texas reversed the court of appeals' judgment and reinstated the trial court's judgment. The court held that under Section 41.003 of the Civil Practice and Remedies Code, a court may not imply a unanimous jury finding in imposing exemplary damages. The burden to secure a unanimous verdict is on the plaintiff and "may not be shifted." The court concluded that the plaintiff bears the burden to obtain the findings necessary to impose exemplary damages, including that the jury is unanimous as to any amount of exemplary damages awarded. It is the plaintiff who must challenge a divided verdict as infirm or in need of clarification. View "OSCAR RENDA CONTRACTING, INC. v. BRUCE" on Justia Law

The case revolves around the interpretation of the term "home" in the context of Medicaid eligibility. The applicants, Clyde and Dorothy Burt, sold their house to their daughter and son-in-law, Linda and Robby Wallace, and moved into a rental property owned by the Wallaces. Later, they moved into a skilled-nursing facility. After moving into the facility, the Burts used their cash assets to buy an undivided one-half interest in the house they had previously sold to the Wallaces. They then executed a Lady Bird deed in favor of the Wallaces, granting their newly acquired one-half interest back to the Wallaces, reserving an enhanced life estate. The Burts then applied for Medicaid assistance, but the Texas Health and Human Services Commission denied their claim, arguing that the property interest was not excluded from the calculation of resources for Medicaid eligibility.The trial court reversed the agency’s determination, and the court of appeals affirmed the trial court's decision. The court of appeals held that a property interest created after admission to a skilled-nursing facility can be excluded from the resources used to determine Medicaid eligibility if the applicant states an intent to live at the property in the future.The Supreme Court of Texas disagreed with the lower courts' interpretation. The court held that a “home” is the applicant’s principal place of residence before the claim for Medicaid assistance arises, coupled with the intent to reside there in the future. A property interest purchased with qualifying resources after the applicant moves to a skilled-nursing facility is an available resource for determining Medicaid eligibility under federal eligibility rules, as the property was not the applicant’s principal place of residence at the time the claim for benefits arose. The court reversed the judgment of the court of appeals and rendered judgment in favor of the Commission. View "TEXAS HEALTH AND HUMAN SERVICES COMMISSION v. ESTATE OF CLYDE L. BURT" on Justia Law

The case revolves around a personal injury claim filed by Hannah Tanner against Texas State University. Tanner was injured on October 4, 2014, when she was thrown from a golf cart on the University campus. She filed a lawsuit against the University, the Texas State University System, and Dakota Scott, a University employee who was driving the golf cart, on September 29, 2016, just before the two-year statute of limitations for personal injury actions was set to expire. However, Tanner did not serve the University until May 20, 2020, several years after the statute of limitations had run.The University argued that Tanner's lawsuit should be dismissed for lack of jurisdiction because she did not serve the University until after the statute of limitations had expired. The University contended that timely service of process is a statutory prerequisite to a suit against a governmental entity, and Tanner did not satisfy this prerequisite. The district court granted the University's plea to the jurisdiction, but the court of appeals reversed, holding that untimely service does not pose a jurisdictional issue that a plea to the jurisdiction can resolve.The Supreme Court of Texas disagreed with the court of appeals' conclusion. The court held that the statute of limitations, including the requirement of timely service, is jurisdictional in suits against governmental entities. Therefore, the University's plea to the jurisdiction was a proper vehicle to address Tanner's alleged failure to exercise diligence in serving the University. However, the court declined to determine whether the district court properly granted the plea. Instead, the court reversed the court of appeals' judgment and remanded the case for that court to determine whether Tanner's service on Scott excuses her from the duty to serve the University. View "TEXAS STATE UNIVERSITY v. TANNER" on Justia Law

In 2020, Luke Hogan, a graduate student at Southern Methodist University (SMU), found his final semester disrupted by the COVID-19 pandemic. Like many institutions, SMU shifted to online classes in response to government lockdown orders. Hogan, feeling cheated out of the in-person educational experience he had paid for, sued SMU for breach of contract. He sought a refund of his tuition and fees, arguing that the shift to online learning constituted a breach of SMU's promise of in-person education.The federal district court sided with SMU, and Hogan appealed. The Fifth Circuit then certified a question to the Supreme Court of Texas: Does the application of the Pandemic Liability Protection Act (PLPA) to Hogan’s breach-of-contract claim violate the retroactivity clause in article I, section 16 of the Texas Constitution? The PLPA, enacted in 2021, protects schools from monetary liability for altering their activities in response to the pandemic.The Supreme Court of Texas held that the application of the PLPA to Hogan's claim does not violate the Texas Constitution's prohibition on retroactive laws. The court reasoned that Hogan did not have a settled expectation of recovering damages from SMU under these circumstances. The court noted that the common law has traditionally excused a party from performing a contract when performance is rendered impossible by an act of God or government. The court also pointed out that Hogan voluntarily accepted SMU's offer to complete his degree online without a corresponding offer of tuition refunds or reduced fees. Therefore, any right of recovery that might have existed for Hogan was speculative and untested prior to the PLPA's enactment. The court concluded that the PLPA, enacted to resolve legal uncertainty created by the pandemic, did not upset Hogan's settled expectations and thus did not violate the constitutional prohibition on retroactive laws. View "HOGAN v. SOUTHERN METHODIST UNIVERSITY" on Justia Law

The case involves successors in interest of mineral-rights holders who sued in 2019 to declare a 1999 judgment foreclosing on their predecessors’ property for delinquent taxes as void. They argued that there was constitutionally inadequate notice of the foreclosure suit, rendering the foreclosure judgment and the tax sale that followed both void. The current owners sought traditional summary judgment based on the Tax Code’s command that an action relating to the title to property against the purchaser of the property at a tax sale may not be commenced later than one year after the date that the deed executed to the purchaser at the tax sale is filed of record.The trial court granted the current owners' motion for summary judgment, and the court of appeals affirmed. The majority held that the sheriff’s deed conclusively established the accrual date for limitations, so the burden shifted to the successors to adduce evidence raising a genuine issue of material fact as to whether there was a due-process violation that could render the statute of limitations inoperable. Because the successors relied only on their arguments and presented no evidence of a due-process violation, the majority concluded, the current owners were entitled to summary judgment.The Supreme Court of Texas held that under Draughon v. Johnson, the nonmovant seeking to avoid the limitations bar by raising a due-process challenge bears the burden to adduce evidence raising a genuine issue of material fact about whether the underlying judgment is actually void for lack of due process. Because the nonmovant here adduced no such evidence, the trial court correctly granted summary judgment based on Section 33.54(a)(1). However, the court also noted that the law governing this case has undergone meaningful refinement since the summary-judgment proceedings took place. Given these recent and substantial developments in the relevant law, the court remanded this case to the trial court for further proceedings in the interest of justice. View "GILL v. HILL" on Justia Law

The case involves a dispute between the San Jacinto River Authority (SJRA) and the cities of Conroe and Magnolia, Texas. The SJRA and the cities had entered into contracts obligating the cities to buy surface water from the SJRA. When a disagreement over fees and rates arose, the cities stopped paying their full balances, leading the SJRA to sue the cities for recovery of those amounts. The cities claimed immunity from the suit as government entities.Previously, the trial court had granted the cities' plea to the jurisdiction, and the court of appeals affirmed this decision. The court of appeals held that the SJRA had not engaged in pre-suit mediation as required by the contracts, and therefore, the cities' immunity was not waived.The Supreme Court of Texas disagreed with the lower courts' decisions. The court held that contractual procedures for alternative dispute resolution, such as pre-suit mediation, do not limit the statutory waiver of immunity for contractual claims against local government entities. The court also found that the mediation requirement did not apply to the SJRA's claims. Furthermore, the court rejected the cities' argument that the agreements did not fall within the waiver because they failed to state their essential terms.Consequently, the Supreme Court of Texas reversed the lower courts' decisions and remanded the case back to the trial court for further proceedings to resolve the SJRA's claims on the merits. View "San Jacinto River Authority v. City of Conroe" on Justia Law

The case involves a dispute between a developer, Campbellton Road, Ltd., and the City of San Antonio, specifically the San Antonio Water System (SAWS). The developer entered into a contract with SAWS in 2003, which included an option for the developer to participate in and fund the construction of off-site oversized infrastructure for a municipal water system. The developer planned to develop two residential subdivisions and needed sewer service for them. The contract stated that if the developer decided to participate in the off-site oversizing project, a contract would form, and the developer would earn credits that could be used to satisfy some or all of the collection component of assessed impact fees.The Court of Appeals for the Fourth District of Texas concluded that the Local Government Contract Claims Act did not apply, and therefore did not waive immunity, because there was no agreement for providing services to the system. The court held that the system had no contractual right to receive any services and would not have “any legal recourse” if the developer “unilaterally decided not to proceed.”The Supreme Court of Texas disagreed with the lower court's decision. The Supreme Court held that the Act waived the system’s immunity from suit because the developer adduced evidence that a contract formed when the developer decided to and did participate in the off-site oversizing project. The court found that the contract stated the essential terms of an agreement for the developer to participate in that project, and the agreement was for providing a service to the system that was neither indirect nor attenuated. The Supreme Court reversed the court of appeals’ judgment and remanded the case to the trial court for further proceedings. View "Campbellton Road, Ltd. v. City of San Antonio" on Justia Law