Justia Texas Supreme Court Opinion Summaries

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

Jeanne Ransom sued dentist Jeanine Eaton, alleging that Eaton extracted two teeth in addition to the nine agreed on in a treatment plan. Ransom served Eaton with the required pre-suit notice and included an export report, but Ransom never re-served the expert report after filing suit. After the passage of 120 days, Eaton moved to dismiss Ransom’s suit on the grounds that Ransom failed to serve her with an expert report within the 120-day deadline set forth in the Texas Medical Liability Act (TMLA). The trial court granted the motion to dismiss. The court of appeals affirmed. While Ransom’s petition for review was pending, the Supreme Court decided Hebner v. Reddy. The Supreme Court reversed in the instant case, holding (1) the holding in Hebner compelled the conclusion that Ransom satisfied the TMLA’s expert-report service requirement when she served Eaton with a report concurrent with pre-suit notice; and (2) Eaton waived any objection to the sufficiency of Ransom’s expert report by failing to raise any objection within twenty-one days after filing her original answer. View "Ransom v. Eaton" on Justia Law

Rigney Construction & Development, LLC contracted with Red Dot Building System, Inc. for a portion of a school construction project. A dispute arose as to the scope of the work Red Dot was to perform under the contract. Red Dot later sued Rigney in Henderson County district court for an unpaid invoice. Thereafter, Rigney sued Red Dot in Hidalgo County. All of the claims related to the contract with Red Dot. Red Dot asked the Hidalgo County court to transfer the suit to Henderson County or abate the suit. The Hidalgo County court denied the motions to transfer and abate. Both courts set their cases for trial. Red Dot sought mandamus relief and, alternatively, asked the Supreme Court to instruct the Hidalgo County court to transfer its case to Henderson County or to abate the Hidalgo County suit. The Supreme Court granted mandamus relief insofar as Red Dot asked the Court to order the Hidalgo County court to transfer the case to Henderson County, holding that Hidalgo County court should have abated the suit pending in that court because Henderson County court acquired dominant jurisdiction. View "In re Red Dot Building System, Inc." on Justia Law

In 2003, the county court appointed Beatriz Burton guardian of the person and estate of Ryan Keith Tonner, who was incapacitated due to an intellectual disability. Burton died in 2007. In 2012, guardianship was transferred to Lubbock County. One month later, Disability Rights Texas filed an application on Tonner’s behalf to fully or partially restore his capacity. The trial court dismissed the application, concluding that Tonner’s capacity was not restored, and that although his named guardian had died, her powers and duties “will remain unchanged.” The court of appeals affirmed. The Supreme Court affirmed on other grounds, holding that the lower courts could not determine whether Tonner’s capacity should be partly restored without appointing a successor guardian, which Tonner did not seek. View "In re Guardianship of Ryan Keith Tonner" on Justia Law

Plaintiffs, who owned insurance policies with National Lloyds Insurance Company, filed independent lawsuits against National Lloyds, claiming they were underpaid on claims following two hail storms in Hidalgo County. The Multidistrict Litigation Panel of Texas (MDL Panel) granted the motions of other insurance carriers seeking to transfer cases arising from the hail storms to a pretrial court and subsequently transferred Plaintiffs’ claims to the same pretrial court. At issue in this case was National Lloyd’s failure to produce certain information requested by Plaintiffs. The pretrial court entered an order compelling National Lloyds to produce six categories of documents, including “management reports and emails,” and assessed sanctions for attorney’s fees. National Lloyds sought mandamus relief, asserting that the compelled discovery was overbroad. The Supreme Court conditionally granted mandamus relief, holding (1) the pretrial court abused its discretion in compelling production of the management reports and emails; and (2) because the pretrial court’s order was overboard as the management reports and emails, but because National Lloyds failed to produce five other categories of discovery, the sanctions award must be reevaluated. View "In re National Lloyds Insurance Co." on Justia Law