Justia Texas Supreme Court Opinion Summaries

At issue was whether a private university that operates a state-authorized police department is a “governmental unit” for purposes of Tex. Civ. Prac. & Rem. Code 51.014(a)(8), which provides for an interlocutory appeal from an order that “grants or denies a plea to the jurisdiction by a governmental unit.” The private university in this case was the University of the Incarnate Word (UIW), and the case arose from an UIW officer’s use of deadly force following a traffic stop. The parents of the UIW student killed in the incident sued UIW for their son’s death. UIW raised governmental immunity as a defense and asked the trial court to dismiss the suit in a plea to the jurisdiction. The trial court denied the plea. UIW took an interlocutory appeal under section 51.014(a)(8). The court of appeals dismissed the appeal. The Supreme Court reversed, holding that UIW is a governmental unit for purposes of law enforcement and is therefore entitled to pursue an interlocutory appeal under section 51.014(a)(8). View "University of the Incarnate Word v. Redus" on Justia Law

Plasma Fab, LLC obtained a general liability insurance policy from Scottsdale Insurance Company and financed the policy with BankDirect Capital Finance, LLC. The agreement between BankDirect and Plasma Fab granted BankDirect authority, upon Plasma Fab’s default, to cancel the insurance policy after proper notice has been mailed under section 651.161 of the Texas Premium Finance Act (Act). Because Plasma Fab was habitually late in making premium payments BankDirect eventually sent notice of intent to cancel the policy. The notice, however, violated section 651.161(b) because BankDirect failed to comply with the Insurance Code’s ten-day notice requirement. Plasma Fab was subsequently sued for damages arising out of a fire, and Scottsdale denied coverage. Plasma Fab sued Scottsdale and BankDirect for breach of contract, arguing that Defendants had no right to cancel the policy because BankDirect mailed its notice one day late. The trial court granted summary judgment to Scottsdale and BankDirect. The court of appeals reversed as to Plasma Fab’s claims against BankDirect due to BankDirect’s failure to mail proper notice. On Appeal, BankDirect argued that the Supreme Court should adopt a “substantial compliance” approach to the Act. The Supreme Court affirmed, holding that, when decoding statutory language, the court is bound by the legislature’s prescribed means, not its presumed intent. View "Bankdirect Capital Finance, LLC v. Plasma Fab, LLC" on Justia Law

Bartush-Schnitzius Foods Co., a food-product manufacturer, entered into an agreement with Cimco Refrigeration, Inc., a refrigeration contractor, to install a new refrigeration system. When disputes arose over the refrigeration system and payments owed, Cimco sued to recover the balance owed on the contract. The jury found that both parties failed to comply with the terms of the agreement. The trial court, however, rendered judgment solely for Bartush. The court of appeals reversed and remanded for entry of judgment that Bartush take nothing and Cimco recover damages. The Supreme Court reversed, holding that both the trial court and the court of appeals failed to render judgment in accordance with the jury’s verdict. Remanded. View "Bartush-Schnitzius Foods Co. v. Cimco Refrigeration, Inc." on Justia Law

At issue in this case was whether the Commerce Clause’s limitations on a state’s power to tax interstate commerce bar property taxes levied on natural gas held in Texas without a destination while awaiting future resale and shipment to out-of-state customers. The court of appeals found the tax in this case valid. The Supreme Court affirmed, holding (1) a nondiscriminatory tax on surplus gas held for future resale does not violate the Commerce Clause; and (2) the tax levied in this case withstands constitutional scrutiny, and because it does not violate the Commerce Clause, neither does it violate Tex. Tax Code 11.12, which provides a state-law exemption for taxes that would otherwise violate federal law. View "Etc Marketing, Ltd. v. Harris County Appraisal District" on Justia Law

At issue in this case was whether a resident physician was entitled to dismissal of a malpractice claim on grounds that she was an employee of a governmental unit. Shana Lenoir died after receiving prenatal care at the University of Texas Physicians Clinic. Shana’s family filed a medical malpractice action against Dr. Leah Anne Gonski, a second-year medical resident who treated Shana. The trial court granted Gonski’s motion to dismiss, concluding that the election-of-remedies provision of the Tort Claims Act warranted dismissal because Gonski was an employee of the University of Texas System Medical Foundation, a governmental unit. The court of appeals reversed, concluding that Gonski failed to establish that she was an employee of the Foundation. The Supreme Court affirmed, holding that Gonski was not an employee of the Foundation under the Tort Claims Act. View "Marino v. Lenoir" on Justia Law

Laura Murphy, who at the relevant period worked as an independent practitioner under contract with West Texas OB Anesthesia, filed claims against El Paso Healthcare System, d/b/a Las Palmas Medical Center, for statutory retaliation and tortious interference with the continuation of the business relationship between Murphy and West Texas OB. The trial court entered judgment on the jury’s verdict, which found El Paso Healthcare liable on both causes of action and awarded $631,000 in damages. The court of appeals affirmed. The Supreme Court reversed the judgment of the court of appeals and rendered judgment that Murphy take nothing on her claims, holding that Murphy failed to establish that El Paso Healthcare illegally retaliated against her or interfered with her legal rights under her existing agreement with West Texas OB. View "El Paso Healthcare System, Ltd. v. Murphy" on Justia Law

After BP America Production turned of the well valve to a gas well, Red Deer Resources, LLC, the top-lease holder, filed suit, asking the trial court to declare that BP’s lease had terminated. The jury found that the well was incapable of production in paying quantities the day after BP closed the valve and eight days after the last gas was sold or used. Based on these findings, the trial court declared that BP’s lease had lapsed and terminated, thus terminating BP’s lease in its secondary term. The court of appeals affirmed. The Supreme Court reversed the judgment of the court of appeals and rendered a take-nothing judgment in favor of BP, holding that because Red Deer never obtained a finding that the well was incapable of production in paying quantities on the material date under the plain language of the lease, BP’s lease remained valid. View "BP America Production Co. v. Red Deer Resources, LLC" on Justia Law

Plaintiffs sued their former attorneys and the law firm at which they practiced alleging legal malpractice arising from prior litigation. The trial court granted summary judgment in Defendants’ favor without specifying the grounds. The court of appeals affirmed the summary judgment, concluding that no summary judgment evidence existed to raise a material fact issue as to causation, an essential element of a legal malpractice claim. The Supreme Court affirmed, holding (1) the court of appeals did not err in applying the but-for causation test to Plaintiffs’ malpractice claims; and (2) summary judgment was properly granted because the evidence failed to raise a material fact issue as to the causation element of Plaintiffs’ negligence claims. View "Rogers v. Zanetti" on Justia Law

At issue in this case was how the harm likely to result from a malicious prosecution should be evaluated in calculating exemplary damages. The Supreme Court held that the potential harm analysis should focus only on the probable damages resulting from malicious prosecution, not the consequences of wrongful imprisonment. Defendant in this case failed to meet his burden of proving that the criminal justice system would ultimately fail to resolve this case correctly where the chances of wrongful imprisonment were essentially zero given the expired statute of limitations. Therefore, the court of appeals erred in considering imprisonment-related damages. The Supreme Court remanded the exemplary-damages award to the court of appeals for a more substantial remittitur. View "Bennett v. Grant" on Justia Law

Tex. Civ. Prac. Rem. Code 150.002 provides that if an expert affidavit in a lawsuit or arbitration for damages arising out of the provision of professional services by licensed or registered professionals is not filed in accordance with the statute, the trial court shall dismiss the claim, and the dismissal may be with prejudice. The Supreme Court held that the statute affords trial courts discretion to dismiss either with or without prejudice. In this case, the statute required dismissal of the amended petition against Defendant. The trial court dismissed the claims without prejudice, but the court of appeals dismissed them with prejudice because, while the amended petition was accompanied by an expert affidavit, an expert affidavit was not filed with the original petition. The Court held that the trial court did not abuse its discretion by dismissing the claims with prejudice, as the record did not conclusively demonstrate that Plaintiff’s claims lacked merit or that the trial court’s decision violated any guiding rules and principles and therefore was an abuse of discretion. View "Pedernal Energy, LLC v. Bruington" on Justia Law