Justia Texas Supreme Court Opinion Summaries

In dispute in this case were 1991 deeds purporting to pass title of all the grantors’ mineral interests in Harrison County to Petitioners. In 2011, the grantors deed to Respondent the same interests they had conveyed to Petitioners. Respondent then sued Petitioners to quiet title to mineral interests, asserting that the property descriptions and general granting clause in the 1991 deeds were insufficient to satisfy the Statue of Frauds because the property conveyed was not identified with reasonable certainty. The trial court granted summary judgment for Petitioners on the title issue and rendered a take-nothing judgment against Respondent. The court of appeals reversed, concluding that the general granting clause was ambiguous. The Supreme Court reversed and rendered judgment that Respondent take nothing, holding that the general grants in the 1991 deeds were valid and unambiguous, conveying title of the grantors’ Harrison County mineral interests to Petitioners. View "Davis v. Mueller" on Justia Law

The Supreme Court took the opportunity in these consolidated mandamus proceedings to provide further clarity regarding electronically stored information (ESI) discovery.In this dispute, the requesting party sought ESI in native form while the responding party offered to produce the ESI in searchable static form, which the responding party asserted was more accessible and convenient given its routine business practices. The trial court ordered production in native form subject to a showing of infeasibility. The court of appeals denied mandamus relief. The Supreme Court denied the petitions for mandamus relief without prejudice, offering the responding party an opportunity to once again object to the discovery in light of this opinion, holding that evidence that a reasonably usable alternative form of ESI is readily available gives rise to the need for balancing, and if the factors outlined in this opinion preponderate against production in the requested form, the trial court may order production as requested under certain circumstances, but otherwise the responding party need only produce the data reasonably available in the ordinary course of business in reasonably usable form. View "In re State Farm Lloyds" on Justia Law

A jury awarded Plaintiff future lost profits based on Defendants’ failure to comply with their covenants not to compete and covenants not to solicit. The jury also awarded Plaintiff exemplary damages and attorney fees. The trial court awarded Plaintiff the full amount of damages. The court of appeals reversed and rendered a take-nothing judgment in part and remanded in part, concluding, inter alia, that the evidence was legally insufficient to support the jury’s award of future lost profits and that the exemplary damages award was unconstitutionally excessive. The Supreme Court affirmed in part and reversed in part, holding (1) the court of appeals did not err in concluding that the evidence of future lost profits was legally insufficient; (2) the court of appeals’ remitted exemplary damages award was unconstitutionally excessive; and (3) the court of appeals properly found that remand of the issue of attorney’s fees was proper. The court remanded the case to the court of appeals so that it may reconsider its suggested remittitur of exemplary damages. View "Horizon Health Corp. v. Acadia Healthcare Co." on Justia Law

The court of appeals misapplied the rule that, at trial, a presumption operates to establish a fact until rebutted but not in summary judgment proceedings.Petitioner sued Respondents (the Railway) for the wrongful death of her husband and minor son. Several family members joined in the action, and all the plaintiffs (collectively, Chavez) were represented by the same law firm. After a trial, a verdict was rendered for the defense, but the trial court granted Chavez’s motion for new trial. Counsel for both sides reached a letter settlement agreement. Chavez then fired the firm that had been represented her. The trial court rendered judgment on the settlement agreement. The Railway then filed the settlement agreement and sued for breach. Chavez asserted that she had not consented to the settlement. The trial court granted summary judgment for the Railway. The court of appeals affirmed because the record established that the settlement agreement was signed by one of her lawyers. The Supreme Court reversed, holding that the Railway did not meet its burden of establishing affirmatively that there was no genuine issue of material fact that Chavez’s law firm was authorized to execute the settlement agreement. View "Chavez v. Kansas City Southern Railway Co." on Justia Law

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