Justia Texas Supreme Court Opinion Summaries

The common law rule against perpetuities does not invalidate a grantee’s future interest in the grantor’s reserved non-participating royalty interest (NPRI). In addition, section 91.402 of the Texas Natural Resources Code does not preclude a lessor’s common law claim for breach of contract.The court of appeals concluded that the rule did not bar the grantees’ future interest in the NPRI. The court, however, found that the reservation’s savings clause was ambiguous and remanded the case for a jury to determine the proper interpretation. The court held that section 91.402 does not bar a claim for breach of contract. Finally, while determining that several of the grantees’ claims failed as a matter of law, the court of appeals upheld the trial court’s award of attorney’s fees against the grantor pursuant to Tex. R. Civ. P. 91a. The Supreme Court affirmed. View "ConocoPhillips Co. v. Koopmann" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the trial court ruling that a will bequest of a tract of land unambiguously devised a fee-simple interest, rather than a life-estate interest, to the testator’s son, entitling the son to summary judgment. The Supreme Court reversed and rendered judgment that the will granted the son a life estate and Petitioners the remainder interest in the property at issue, holding that the contested provision unambiguously conveyed a life estate. View "Knopf v. Gray" on Justia Law

In construing a settlement agreement that conditioned resumption of uranium mining operations on restoration of well-water quality if pre-mining data showed the water had been suitable for specified uses before prior mining operations began, the lower courts impermissibly employed surrounding facts and circumstances to determine subjective intent and interpolate constraints not found in the contract’s unambiguous language.Specifically, the lower courts held that, in determining whether a restoration obligation existed as to a disputed well, the mining company was contractually required to ignore data showing no pre-mining suitability. The Supreme court reversed and rendered judgment for the mining company, holding that the court of appeals clearly erred by relying on extrinsic evidence of intent to add to, alter, and augment the settlement agreements plain and unambiguous language. View "URI, Inc. v. Kleberg County" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the trial court’s denial of the City of San Antonio’s plea to the jurisdiction based on governmental immunity from a suit for damages arising out of a collision between a car and a motorcycle.In her suit, Plaintiff alleged that City police officers were negligent in engaging in a high speed chase, that the City had actual notice of her claims, and that the City’s immunity was waived by the Texas Tort Claims Act (TTCA). The trial court denied the City’s plea to the jurisdiction. The court of appeals affirmed, concluding that there was a fact issue as to whether the City had actual notice of Plaintiff’s claims. The City appealed, arguing that the court of appeals applied an erroneous standard. The Supreme Court agreed and dismissed the cause for want of jurisdiction, holding that the City did not have actual notice that it was at fault in connection with the collision, as required by the TTCA for the City’s immunity to have been waived. Therefore, the trial court lacked jurisdiction over the claims. View "City of San Antonio v. Tenorio" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the trial court’s denial of the City of San Antonio’s plea to the jurisdiction based on governmental immunity from a suit for damages arising out of a collision between a car and a motorcycle.In her suit, Plaintiff alleged that City police officers were negligent in engaging in a high speed chase, that the City had actual notice of her claims, and that the City’s immunity was waived by the Texas Tort Claims Act (TTCA). The trial court denied the City’s plea to the jurisdiction. The court of appeals affirmed, concluding that there was a fact issue as to whether the City had actual notice of Plaintiff’s claims. The City appealed, arguing that the court of appeals applied an erroneous standard. The Supreme Court agreed and dismissed the cause for want of jurisdiction, holding that the City did not have actual notice that it was at fault in connection with the collision, as required by the TTCA for the City’s immunity to have been waived. Therefore, the trial court lacked jurisdiction over the claims. View "City of San Antonio v. Tenorio" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the decisions of the trial court and court of appeals agreeing with Plaintiffs that a local water district owned an open-space area at Medina Lake the community had long considered public space for recreation and access to the lake. Plaintiffs, three families who owned lots on a peninsula at Medina Lake, filed suit after new neighbors, who claimed that they owned the open-space area and that the community members had no easements or other rights to use it, denied Plaintiffs access to the disputed area. The trial court declared that the new neighbors did not own the open-space. The Supreme Court agreed, holding (1) the new neighbors did not own the disputed area, and therefore, they had no standing to challenge Plaintiffs’ alleged easement over that area or authority to exclude Plaintiffs from the area; but (2) the court of appeals erred in upholding the award of attorney’s fees to the water district. View "Lance v. Robinson" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the district court’s dismissal of Petitioner’s appeal of an adverse ruling by the Texas Commission on Environmental Quality (TCEQ) for failing to serve citation on the TCEQ within thirty days of filing the petition on the district court as required by the Texas Clean Air Act, see Tex. Health & Safety Code 382.032, holding that the Act did not require dismissal under the circumstances of this case.Petitioner did not formally serve the TCEQ until fifty-eight days after filing its petition with the district court. The district court dismissed Petitioner’s request for judicial review. The court of appeals upheld the dismissal. In reversing, the Supreme Court held (1) the Clean Air Act, rather than the Water Code, controlled Petitioner’s request for judicial review in the district court, and therefore, the thirty-day service requirement was applicable; and (2) because the Legislature expressed no particular consequence for failing to meet the thirty-day statutory deadline and none was logically necessary, the Legislature’s presumed intent was that the requirement be directory rather than mandatory and that late service did not result in the automatic dismissal of Petitioner’s appeal. View "AC Interests L.P. v. Texas Commission on Environmental Quality" on Justia Law

The lessee of certain mineral interests could not justifiably rely on extra-contractual representations by the lessor’s agent despite “red flags” and a negation-of-warranty clause in the sales documents explicitly placing the risk of title failure on the lessee.In its complaint, the lessee alleged breach of contract, fraud, and negligent misrepresentation. Following a pre-trial conference, the trial court issued an order under Tex. R. Civ. P. 166(g) disposing of all of the lessee’s claims, concluding (1) the unambiguous terms of the letter of intent and leases precluded the lessee’s contract claim; and (2) as a matter of law, the lessee could not establish the justifiable-reliance element of its fraud and negligent-misrepresentation claims. The court of appeals affirmed the trial court's ruling regarding the contract claim but reversed on fraud and negligent misrepresentation. The Supreme Court reversed the court of appeals and reinstated the trial court’s judgment, holding (1) justifiable reliance was an essential element of the lessee’s remaining causes of action; and (2) as a matter of law, the lessee could not show justifiable reliance. View "JPMorgan Chase Bank, N.A. v. Orca Assets G.P., LLC" on Justia Law

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