Justia Texas Supreme Court Opinion Summaries

Wallace Hall, a regent for The University of Texas System, filed suit against William McRaven in his official capacity as the System’s Chancellor, for McRaven’s refusal to grant Hall complete access to records containing student-admissions information. Hall sought a declaratory judgment that McRaven acted ultra vires in refusing to provide the unredacted information. The trial court granted McRaven’s plea to the jurisdiction and dismissed the case with prejudice, concluding that McRaven’s conduct was not ultra vires and that sovereign immunity required dismissal. The court of appeals affirmed. The Supreme Court affirmed, holding that McRaven did not exceed his authority, and therefore, Hall’s case was properly dismissed. View "Hall v. McRaven" on Justia Law

Elie and Rhonda Nassar filed a claim with Liberty Mutual Insurance Policy under their homeowners’ policy when their property was damaged by Hurricane Ike. Disputes arose over the value of various items of damaged property, and this appeal concerned which party of the Liberty Mutual insurance policy covered the Nassars’ damaged fencing. At issue was the proper interpretation of two policy provisions that separate coverage for the “dwelling” and “other structures.” The trial court entered final judgment in favor of Liberty Mutual, concluding that the Nassars’ fencing was an “other structure.” The court of appeals affirmed. The Supreme Court reversed, holding that the Nassars’ interpretation of the policy language was reasonable and the policy was unambiguous, and therefore, the Nassars’ fencing was covered under the “dwelling” provision as a matter of law. Remanded. View "Nassar v. Liberty Mutual Fire Insurance Co." on Justia Law

Alan Petrie was assaulted and robbed in The Gallery apartment complex’s visitor parking lot. Petrie sued the apartment complex and its owners (collectively, Gallery), alleging that it knew or shown have known about the high crime rate on its premises and in the surrounding area yet failed to use ordinary care to make the complex safe. The trial court concluded that Gallery owed no duty to Petrie. The court of appeals reversed, concluding that there was evidence that Gallery knew or should have known of a foreseeable and unreasonable risk of harm. The Supreme Court reversed, holding that the court of appeals failed to properly consider whether the risk of harm was unreasonable. The Court further rendered judgment in Gallery’s favor because Petrie failed to argue or offer any evidence of the burden that preventing such a crime would impose on Gallery. View "UDR Texas Properties, L.P. v. Petrie" on Justia Law

Wade Brady sued LeaAnne Klentzman and the West Fort Bend Star (collectively, the media defendants) for libel and libel per se, arguing that a newspaper article portrayed him as “unruly and intoxicated” when he interacted with a state trooper. The jury found that some statements in Klentzman’s article were defamatory, that some of the statements were not substantially true, and that Klentzman acted with malice. The jury awarded damages against the media defendants for mental anguish and damage to Wade’s reputation and exemplary damages against Klentzman and the Star. The trial court rendered judgment on the verdict. The court of appeals reversed and remanded for a new trial, concluding (1) the jury charge improperly placed the burden of proving truth on the media defendants; (2) to recover exemplary damages, Wade had to show that the media defendants acted with knowledge of falsity or reckless disregard for the truth; and (3) legally sufficient evidence existed that Wade suffered actual damages. The Supreme Court affirmed, holding that the court of appeals properly remanded the case for a new trial so the jury could evaluate the evidence under the proper standard. View "Brady v. Klentzman" on Justia Law

During their marriage, Respondent and Petitioner produced one child and a $30 million marital estate. During marriage-dissolution proceedings, the parties executed two agreements settling all issues. The trial court orally approved the settlement agreements and granted the divorce petitions, and more than one year passed before the trial court’s rulings were reduced to writing in a final divorce decree. Petitioner filed several post-judgment motions challenging the decree, arguing that the child support and child custody provisions in the final decree materially deviated from the parties’ agreement. The trial court substantially denied Petitioner relief. Petitioner appealed, challenging the property division and child welfare provisions of the divorce decree. Applying the estoppel-based acceptance-of-benefits doctrine, which preludes a litigant from challenging a judgment after voluntarily accepting the judgment’s benefits, the court of appeals dismissed the appeal. The Supreme Court reversed, holding (1) the acceptance-of-benefits doctrine is a fact-dependent, estoppel-based doctrine focused on preventing unfair prejudice to the opposing party; and (2) the factors informing the equitable inquiry did not favor an estoppel in this case. View "Kramer v. Kastleman" on Justia Law

Denbury Green Pipeline-Texas, LLC was formed to build and operate a carbon dioxide pipeline known as “the Green Line” as a common carrier in Texas. Denbury Green filed a permit application with the Texas Railroad Commission to obtain common carrier status, which would give it eminent domain authority pursuant to the Texas Natural Resources Code. The Railroad Commission granted Denbury Green the permit. Denbury Green then filed suit against Texas Rice Land Partners, Ltd., James Holland, and David Holland (collectively, Texas Rice) seeking an injunction allowing access to certain real property so that it could complete a pipeline survey. While the suit was pending, Denbury Green took possession of Texas Rice’s property and then surveyed for and constructed the Green Line. The trial court granted summary judgment to Denbury Green. On remand, the court of appeals reversed, concluding that reasonable minds could differ regarding whether, at the time Denbury Green intended to build the Green Line, a reasonable probability existed that the Green Line would serve the public. The Supreme Court reversed, holding that Denbury Green is a common carrier as a matter of law because there was a reasonable probability that, at some point after construction, the Green Line would serve the public, as it does currently. View "Denbury Green Pipeline-Texas, LLC v. Texas Rice Land Partners, Ltd." on Justia Law

In 2002, the Public Utilities Regulatory Act (PURA) implemented a competitive retail market for electricity in the Electric Reliability Council of Texas. Each incumbent, vertically integrated electric utility within the market was required to unbundle its business activities into separate units, including a transmission and distribution utility (TDU). Of the units, only TDUs continued to be regulated by the Public Utilities Commission (PUC). Here, several parties to a TDU ratemaking proceeding sought judicial review of the PUC’s order. The Supreme Court affirmed in part and reversed in part the judgment of the court of appeals, holding (1) PURA section 36.351, which requires electric electric utilities to discount charges for service provided to state college and university facilities, does not apply to TDUs; (2) former PURA section 36.060(a), which required an electric utility’s income taxes to be computed as though it had filed a consolidated return with a group of its affiliates eligible to do so under federal tax law, did not require a utility to adopt a corporate structure so as to be part of the group; and (3) the evidence in this matter established that franchise charges negotiated by the TDU with various municipalities were reasonable and necessary operating expenses under PURA section 33.008. View "Oncor Electric Delivery Co. v. Public Utility Commission of Texas" on Justia Law

A subcontractor sued a premises owner for personal injuries the subcontractor suffered while working with a contractor on the owner’s premises. A jury found that the owner, contractor, and subcontractor all negligently caused the accident. The jury assigned seventy-five percent of the responsibility to the owner, fifteen percent to the contractor, and ten percent to the subcontractor. The owner appealed. The Supreme Court reversed and rendered judgment in favor of the premises owner, holding that no evidence supported either of the theories on which the jury found the premises owner liable. Remanded. View "4Front Engineered Solutions, Inc. v. Rosales" on Justia Law

This case involved a contract dispute between a local governmental entity that oversaw federal funded rebuilding projects in areas of Texas that were struck by Hurricane Ike and a construction contractor. After a dispute arose between the governmental entity and the contractor regarding the quality of the contractor’s work and payment due under the contracts, the contractor filed suit against the governmental entity for payments allegedly due. The governmental entity filed a plea to the jurisdiction, alleging governmental immunity. The trial court denied the plea, concluding that immunity had been waived by chapter 271 of the Local Government Code, which waives immunity if the contract provides “goods or services to the local governmental entity.” The court of appeals reversed. The Supreme Court reversed, holding that that the chapter 271 immunity waiver applied in this case. View "Byrdson Services, LLC v. South East Texas Regional Planning Commission" on Justia Law

James Wetherbe, a Texas Tech professor and associate dean, filed a defamation action against Debra Laverie, a colleague, after Wetherbe was passed over for promotion. Laverie filed a motion for summary judgment, arguing that the Tort Claims Act required Wetherbe to name Texas Tech as a defendant and dismiss her from the lawsuit. Wetherbe responded that because Laverie did not act in the scope of her employment when she defamed him she was not entitled to dismissal. The trial court denied Laverie’s motion. The court of appeals affirmed. The Supreme Court reversed and rendered judgment dismissing Laverie from the underlying suit, holding that Laverie was acting in the scope of her employment when she made the allegedly defamatory statements. View "Laverie v. Wetherbe" on Justia Law