Justia Texas Supreme Court Opinion Summaries

While the Supreme Court was asked in this case to recognize tortious interference with an inheritance as a viable cause of action in Texas, the court was not persuaded to consider it because Petitioners and cross-respondents, the Kinsels, had an adequate remedy in this case.In this case involving the sale of a ranch, the Kinsels sought damages for tortious interference with their inheritances, statutory and common-law fraud, and conspiracy. The jury found for the Kinsels on every claim. The court of appeals reversed the trial court’s award of damages for tortious interference with an inheritance on the basis that neither the Texas legislature nor the Supreme Court has recognized that cause of action. On appeal, the Kinsels urged the Supreme Court to recognize tortious interference with an inheritance as a cause of action and uphold their recovery. The Supreme Court upheld the judgment of the court of appeals, holding that the facts of this case did not warrant an enlargement of this state’s body of tort law, as the law provided an adequate remedy in this case - a constructive trust imposed on the disputed inheritance. View "Kinsel v. Lindsey" on Justia Law

When Respondent’s employer received a report that Respondent failed an employment-related drug test, the employer ceased assigning Respondent any work. Respondent filed this lawsuit against his employer, WHM Custom Services, Inc.; the owner of the refinery, Exxon Mobil; and the drug-testing administrator, DISA, Inc. , asserting various claims against each of the three defendants. The trial court granted summary judgment for Defendants on all but one claim, which it dismissed for lack of jurisdiction. The court of appeals reversed and reinstated three of Respondent’s claims against Exxon, four claims against WHM, and two claims against DISA. The Supreme Court reversed in part, vacated in part, and rendered judgment reinstating the trial court’s take-nothing judgment against Respondent, holding that the trial court correctly granted summary judgment for Exxon, WHM, and DISA. View "Exxon Mobile Corp. v. Rincones" on Justia Law

Certain minority shareholders filed suit in a Texas court alleging dilution of equity interests. Defendants responded by invoking a forum-selection clause designating Delaware as the proper forum for disputes arising out of a shareholders agreement. The court of appeals reversed the trial court’s grant of Defendants’ motion to dismiss, concluding that the forum-selection clause did not control because the shareholders’ extracontractual claims did not allege noncompliance or interference with any rights or obligations derived from the shareholders agreement. The Supreme Court reversed and dismissed the shareholders’ claims in part, holding (1) the shareholders’ statutory and common-law tort claims evidence a “dispute arising out of” the shareholders agreement; and (2) the shareholders’ noncontractual claims fell within the forum-selection clause’s scope. View "Pinto Technology Ventures, LP v. Sheldon" on Justia Law

Galveston County Commissioners Court may set a salary range for a county judicial employee while letting Galveston County district judges decide if compensation within that range is reasonable. While the judicial branch may direct the Commissioners Court to set a new range, it cannot dictate a specific salary outside that range.The Supreme Court reversed the court of appeals’ judgment in this long-running dispute over who has the authority to set the compensation of a county judicial employee, holding that, in this case, the trial court lacked the authority to require a county judge to reinstate a county judicial employee at a specific salary, thus encroaching on the county’s legislative branch - the Commissioners Court. View "Honorable Mark Henry v. Honorable Lonnie Cox" on Justia Law

Respondent was a party to an oil and gas lease that restricted its use of the surface estate and required it to drill from off-site locations when feasible. Briscoe Ranch, Inc. owed an adjacent surface estate and agreed that Respondent could use horizontal drilling to drill from the surface of the Ranch in order to produce minerals from Respondent’s lease. The lessee of the minerals underlying the Ranch (Petitioner) was not a party to the agreement and sought to enjoin Respondent from drilling on the Ranch and asserted claims for both trespass and tortious interference with a contract. Petitioner claimed that its consent was necessary before Respondent could drill through the Ranch’s subsurface covered by its mineral lease. The district court dismissed the claim. The Supreme Court affirmed, holding (1) the loss of minerals Petitioner will suffer by a well being drilled through its mineral estate is not a sufficient injury to support a claim for trespass; and (2) Respondent’s drilling plans did not tortiously interfere with Petitioner’s contractual lease rights. View "Lightning Oil Co. v. Anadarko E&P Onshore, LLC" on Justia Law

Petitioners, energy companies, owned four natural gas compressor stations and a metering station outside the town of Dish. In 2011, the town and eighteen of its residents sued the energy companies, alleging trespass and nuisance energies. However, as early as 2006, residents first complained about the noise and odor emanating from these facilities. The trial court entered summary judgment for the energy companies on various grounds, including limitations. The court of appeals reversed the trial court on limitations. The Supreme Court reversed the court of appeals’ judgment and reinstated the trial court’s take-nothing judgment, holding that the two-year statute of limitations barred the residents’ claims. View "Town of Dish v. Atmos Energy Corp." on Justia Law

At issue was whether a newly-elected district court judge or the former judge he or she replaced may file findings of fact following a bench trial over which the former judge presided before his or her term expired. The court of appeals concluded that neither judge could file the findings. The Supreme Court reversed, holding (1) the court of appeals properly found that the new judge could not file the findings because she lacked the authority to file them; but (2) the court of appeal erred by failing to direct the new judge to request that the former judge file the findings because the former judge was the only judge with the power to file findings, even after he left the bench. View "Ad Villarai, LLC v. Pak" on Justia Law

The Supreme Court held that several members of the Harris County Appraisal Review Board were presently or formerly employed by the Harris County Appraisal District (HCAD) under provisions of the Texas Unemployment Compensation Act (TUCA) such that when their workload was reduced or their terms of service ended, they became eligible for unemployment compensation benefits. The Texas Workforce Commission (TWC) determined that the claimants were entitled to unemployment compensation. The district court set the TWC’s decisions aside. The court of appeals reversed. The Supreme Court affirmed, holding (1) the TWC did not arbitrarily or unreasonably ignore its own regulation; (2) the Tax Code does not prohibit or prevent a Board member from being an employee of HCAD for TUCA purposes; and (3) there was substantial evidence to support the TWC’s determination that the claimants were entitled to unemployment compensation. View "Harris County Appraisal District v. Texas Workforce Commission" on Justia Law

Paul Green, a former bus monitor for Dallas County Schools (DCS), was terminated because he admitted to “urinating on [himself] and in a water bottle while onboard [a] school bus[.]” Green filed this lawsuit, alleging that DCS terminated his employment because he was disabled. During trial, the jury heard testimony about Green’s heart condition and the drug he was taking that purportedly caused urinary incontinence. The trial court rendered judgment for Green. The court of appeals reversed, concluding that there was no evidence that DCS fired Green “because of” his disability. The Supreme Court reversed, holding (1) the court of appeals erred by treating Green’s heart condition as his only disability; and (2) the evidence supported a finding that Green was terminated because of a different disability - urinary incontinence. View "Green v. Dallas County Schools" on Justia Law

A plaintiff who was not a party to a written contract was not permitted to enforce the agreement as a third-party beneficiary.DTSG, Ltd. filed suit against First Bank. Richard Brumitt intervened as an additional plaintiff, alleging that he was a third-party-creditor beneficiary of an agreement entered into by DTSG and First Bank. The jury found First Bank liable to both DTSG and Brumitt for breach of contract and for negligent and grossly negligent misrepresentation. The trial court entered judgment based on the jury’s verdict. The Supreme Court reversed the court of appeals’ judgment, holding (1) the agreement between DTSG and First Bank was unambiguous and did not make Brumitt a third-party beneficiary; and (2) the trial court erred by submitting that issue to the jury and by instructing the jury that it could consider extrinsic evidence to add a third-party-beneficiary term to the unambiguous written agreement. The court remanded the case for further consideration of Brumitt’s claims alleging negligent and grossly negligent misrepresentations. View "First Bank v. Brumitt" on Justia Law