Justia Texas Supreme Court Opinion Summaries

The trial court did not abuse its discretion by denying Defendants’ motions to dismiss this health care liability action when it read several experts’ reports together to satisfy the requirement of the Texas Medical Liability Act that Plaintiffs serve each defendant with an “adequate” expert report or face dismissal of their claim. See Tex. Civ. Prac. & Rem. Code 74.351(1).Plaintiff filed health care liability claims against three defendants, alleging that their respective negligence led to her mother’s death. Plaintiff filed four separate expert reports to satisfy the Act’s requirements. Each defendant moved to dismiss Plaintiff’s claims for failure to serve adequate reports. The trial court denied the motions to dismiss. The court of appeals reversed, concluding that Plaintiff’s four reports - even when read together - did not constitute a good-faith effort to show that Plaintiff’s claims had merit. The Supreme Court reversed, holding that Plaintiff’s four expert reports provided enough information for the trial court to conclude that they constituted a good-faith effort. View "Miller v. JSC Lake Highlands Operations, LP" on Justia Law

At issue in this appeal from a slander-of-title judgment was how the special or economic damages should be measured.When Marc Pieroni and Bonnie Allen-Pieroni divorced, Bonnie was awarded $500,000, which Marc paid in monthly installments. Thereafter, Marc purchased a new home, and Bonnie recorded in the county property record an abstract of judgment reflecting Marc’s $500,000 debt from the divorce decree, thus creating an ostensible lien on Marc’s property. When Marc was preparing to close on the sale of his property years later, the sale fell through because Bonnie refused to release her lien. Marc sued Bonnie to quiet title and for damages, asserting an equitable action to remove her lien and a tort action for slander of title. The trial court rendered judgment for Marc and awarded damages of $98,438. The court awarded damages based in part on the difference between the disparaged property’s contract price and the owner’s mortgage balance - the amount the property owner would have received from the property’s sale but for the defendant’s disparagement of his title. The court of appeals affirmed. The Supreme Court reversed, holding that the damages awarded for slander of title were based in part on an erroneous measure and unsupported by the evidence. Remanded. View "Allen-Pieroni v. Pieroni" on Justia Law

If a plaintiff sues both public employees and their employer, section 101.106(e) of the Texas Tort Claims Act requires that the employees be immediately dismissed upon the employer’s motion, and this statutory right to dismissal accrues when the motion is filed and is not impaired by later amendments to the pleadings or motion. Respondent sued a government unit and some of its employees. The Attorney General moved to dismiss all but the tort claims against the employer, arguing that Respondent's contract claim against the employer, a state agency, was barred by sovereign immunity and that the tort claims against the employees were required to be dismissed under section 101.106(e). Thereafter, Respondent amended his petition to drop his tort claims against the employer, leaving the employees as the only tort defendants. The amended petition’s only claim against the employer was for breach of contract. The trial court dismissed Respondent's contract claim against the employer but denied dismissal of his tort claims against the employees. On appeal, the Supreme Court rendered judgment dismissing Respondent's state-law tort claims against the employees, holding that, following Respondent's amended petition, Defendants remained entitled to dismissal of the tort claims asserted against the employees in Respondent's original petition, as requested in Defendants’ original motion to dismiss. View "University of Texas Health Science Center at Houston v. Rios" on Justia Law

In this tort suit arising from a real estate transaction, the Supreme Court conditionally granted mandamus relief to Relators from an order denying leave to designate Plaintiffs’ legal advisors as responsible third parties.Relators’ motion to designate was filed long after an initial trial date but seventy-six days before a new trial setting. The trial court denied the motion to designate without granting leave to replead. The court of appeals denied mandamus relief. The Supreme Court conditionally granted Relators’ petition for writ of mandamus, holding that the trial court erred in denying Relators’ motion because it was filed more than sixty days before the trial setting and the court did not afford Relators an opportunity to cure any pleading deficiency. View "In re Coppola" on Justia Law

The Division of Workers’ Compensation has exclusive jurisdiction over statutory and tort claims alleging the Texas Workers’ Compensation Act’s “bona fide offer of employment” process was misused to fabricate grounds for firing a covered employee.Employee sued Employer’s workers’ compensation carrier and its agent (collectively, Accident Fund), alleging retaliation, conspiracy, and tortious interference claims. Specifically, Employee claimed that Accident Fund participated in the bona-fide-employment-offer-process and that his job offers were “bogus,” thus serving as a pretext for terminating him. Accident Fund filed a plea to the jurisdiction, asserting that exclusive jurisdiction lay with the Division of Workers’ Compensation. The trial court denied the plea. Accident Fund filed a petition for mandamus relief, which the court of appeals denied. The Supreme Court reversed, holding (1) the Division had exclusive jurisdiction over Employee’s claims against Accident Fund; and (2) because Employee did not exhaust administrative remedies through the workers’ compensation administrative process before filing suit, mandamus relief for Accident Fund was appropriate. View "In re Accident Fund General Insurance Co." on Justia Law

At issue in this workers’ compensation was the meaning of the word “issue” as used in Title 5 of the Labor Code.The trial court ruled that Respondent did not suffer a compensable injury and was therefore not entitled to workers’ compensation. The court also granted the State Office of Risk Management’s (SORM) motion for summary judgment on the ground that Respondent violated a statute by working from home. The court of appeals reversed the grant of summary judgment for SORM and affirmed the denial of Respondent’s motion for summary judgment, concluding that because SORM never presented the statutory-violation ground to the appeals panel at the administrative level, the panel necessarily could not have “decided” that “issue,” and therefore, the Labor Code barred the trial court from exercising jurisdiction over SORM’s motion. The Supreme Court affirmed in part and reversed in part, holding (1) the statutory ground SORM argued in its summary judgment motion was an argument supporting resolving in SORM’s favor the issue of whether Respondent was in the course and scope of her employment at the time of her accident, and therefore, SORM was free to raise the statutory argument at any time; and (2) Respondent’s motion for summary judgment was properly denied. View "State Office of Risk Management v. Martinez" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the trial court’s judgment awarding a constructive trust to Longview Energy Company on certain mineral leases and related property and requiring the disgorgement of money derived from past lease production revenues.Longview sued two of its directors and entities associated with them after discovering that one of the entities had purchased mineral leases in an area where Longview had been investigating the possibility of buying leases. The jury found (1) the directors breached their fiduciary duties to Longview by usurping a corporate opportunity and by competing with the corporation without disclosing the competition, and (2) the entity as issue acquired leases as a result of the breaches. The court of appeals reversed. The Supreme Court affirmed, holding (1) there was no evidence tracing the entity’s acquisition of any specific leases to any assumed breaches, and therefore, the trial court erred by imposing the constructive trust on and requiring the transfer of leases and properties to Longview; and (2) there was no evidence to support the trial court’s damages award. View "Longview Energy Co. v. Huff Energy Fund LP" on Justia Law

At issue in this discovery dispute arising in the context of multidistrict litigation (MDL) involving allegations of underpaid homeowner insurance claims was whether a party’s attorney-billing information is discoverable when the party challenges an opposing party’s attorney-fee request as unreasonable or unnecessary but neither uses its own attorney fees as a comparator nor seeks to recover any portion of its own attorney fees. The MDL pretrial court ordered the insurer in this case to respond to the discovery requests. The Supreme Court conditionally granted mandamus relief and directed the trial court to vacate its discovery order, holding (1) compelling en masse production of a party’s billing records invades the attorney work-product privilege; (2) the privilege is not waived simply because the party resisting discovery has challenged the opponent’s attorney-fee request; and (3) such information is generally not discoverable. View "In re National Lloyds Insurance Co." on Justia Law

The Supreme Court reversed in part the judgment of the court of appeals, which dismissed Petitioners’ appeal for lack of jurisdiction, holding that Petitioners timely filed their interlocutory appeal.Respondent filed suit against several parties, including Petitioners - municipal development corporations (MDCs) - alleging that negligent construction of a municipal hiking and walking path caused damming, resulting in damage to his property. Petitioners filed a motion to dismiss and plea to the jurisdiction, arguing that Respondent’s claims lacked a jurisdictional basis. The trial court granted the motion to dismiss as to some claims but denied relief as to all other claims. The MDCs subsequently filed a motion for summary judgment on the remaining claims for injunctive relief, arguing that Respondent’s claims lacked a jurisdictional basis and evidentiary merit. The trial court denied the motion, and the MDCs appealed. The court of appeals dismissed the MDCs’ appeal for lack of appellate jurisdiction. The Supreme Court reversed in part, holding that the MDCs’ hybrid motion for summary judgment was not a mere motion for reconsideration but, rather, a distinct motion that merited an independent twenty-day interlocutory appeal period. View "City of Magnolia 4A Economic Development Corp. v. Smedley" on Justia Law

At issue in this appeal from a Title IV-D associate judge’s order modifying conservatorship and child support for three children was whether the Title IV-D associate judge had authority to enter an order modifying conservatorship.The court of appeals reversed the associate judge’s order on the ground that the Title IV-D associate judge had no authority to enter an order modifying conservatorship before recent amendments to the Family Code to expressly grant Title IV-D associate judges such authority. The court of appeals also reversed on the independent ground that the associate judge erred by failing to consider the children’s father’s request to participate in the hearing remotely from prison. The Supreme Court affirmed solely on the independent ground that the associate judge failed to consider Father’s request to participate in the hearing by alternative means. The court, however, disagreed with the court of appeals’ ruling that the Title IV-D associate judge lacked authority to enter the order modifying conservatorship and child support, holding that the former version of the Texas Family Code grants Title IV-D associate judges authority to modify conservatorship when, as here, the modification relates to the establishment, enforcement, or modification of a child-support obligation. View "Office of Attorney General of Texas" on Justia Law