Justia Texas Supreme Court Opinion Summaries

Plaintiffs filed suit against Crosstex North Texas Pipeline, LP asserting that Crosstex had both intentionally and negligently created a nuisance. Specifically, Plaintiffs alleged that a compressor station built by Crosstex had greatly diminished the value of their ranch and ruined their financial investment, as well as their ability to use and enjoy their land. A jury found that Crosstex had “intentionally and unreasonably” created a nuisance as to Plaintiffs’ ranch, that the nuisance was permanent, and that the nuisance caused the ranch’s fair market value to decline by over $2 million. The trial court rendered judgment on the jury’s verdict. The court of appeals reversed, concluding that the evidence was not factually sufficient to support the jury’s finding of a negligently created nuisance. The Supreme Court clarified the law and affirmed, holding holding (1) the term “nuisance” refers to a type of legal injury involving interference with the use and enjoyment of real property but does not describe a cause of action; and (2) a defendant can be liable for intentionally or negligently causing a condition that constitutes a nuisance, and neither claim requires a separate finding that the defendant unreasonably used its property when creating a nuisance. View "Crosstex N. Texas Pipeline, LP v. Gardiner" on Justia Law

Bonnie Jones was injured during the course of her employment. Her employer’s comp carrier, American Home Assurance Company, paid her various benefits but did not pay her supplemental income benefits (SIBs) for the fourteenth quarter of 2011. Jones sued, and the parties settled. Under the Texas workers’ compensation regime, where SIBs are concerned, settlements cannot bypass a statutory formula or facilitate benefits were none were due as a matter of law. In this case, the settlement was noncompliant. The trial court approved the proposed settlement, and the court of appeals affirmed. The Supreme Court reversed, holding that a court cannot condone a noncompliant settlement regarding an SIBs award. View "Tex. Dep’t of Ins., Div. of Workers’ Comp. v. Jones" on Justia Law

Plaintiff, an employee of Union Pacific Railroad, contracted West Nile virus from a mosquito bite. Plaintiff sued Union Pacific under the Federal Employers’ Liability Act (FELA) for failing to provide a safe workplace. The jury found that both Plaintiff and Union Pacific negligently caused his disease and attributed eighty percent responsibility to Union Pacific. The trial court rendered judgment on the verdict. Union Pacific appealed, arguing that under the common-law doctrine of ferae naturae, which limits a property owner’s liability for harm from indigenous animals that he has not attracted to the property, it owed Plaintiff no legal duty to protect him from mosquitoes. The Supreme Court reversed, holding that the doctrine of ferae naturae applied in this case and precluded Union Pacific’s liability. View "Union Pacific Railroad Co. v. Nami" on Justia Law

Michael and Laura McIntyre, along with their children that were homeschooled, were criminally charged with contributing to truancy and failure to attend school. The McIntyres sued the District and its attendance officer, alleging that Defendants violated the McIntyres’ rights under both the Texas Constitution and United States Constitution. The District filed pleas, exceptions, and motions arguing that the McIntyres failed to exhaust their administrative remedies. The attendance officer invoked qualified immunity. The trial court denied relief. The court of appeals reversed in part and (1) dismissed the McIntyres’ state-law claims against the District and its attendance officer for the McIntyres’ failure to “exhaust their administrative remedies, and (2) dismissed the federal-law claims against the attendance officer based on qualified immunity. The Supreme Court (1) affirmed the judgment of the court of appeals to the extent it dismissed Plaintiffs’ claims based on qualified immunity; but (2) reversed the judgment insofar as it dismissed the McIntyres’ claims for failure to exhaust administrative remedies, holding the Texas Education Code does not require administrative appeals when a person is allegedly aggrieved by violations of laws other than the state’s school laws, such as the state and federal Constitutions. View "McIntyre v. El Paso Indep. Sch. Dist." on Justia Law

In 2001, Preston and Victoria Oschner divorced. The trial court ordered that Preston pay Victoria monthly child support. The child support order required Preston to make payments to his daughter’s school and, when she switched schools, to make payments through a registry. Preston, however, paid the new school directly and paid more than $20,000 above the total amount that the child-support order contemplated through the registry. Almost a decade later, Victoria brought a child-support enforcement action against Preston to recover the balance that Preston failed to pay through the registry. The trial court ruled in favor of Preston, concluding that the direct tuition payments satisfied the child-support obligation. The court of appeals reversed, concluding that the trial court was barred from considering Preston’s direct tuition payments when confirming the amount of arrearages. The Supreme Court reversed, holding (1) a trial court in a child-support enforcement proceeding may consider evidence of direct payments like those in this case that were made when confirming the amount of arrearages; and (2) the trial court did not abuse its discretion in determining that the support Preston provided discharged his obligation. View "Ochsner v. Ochsner" on Justia Law

Plaintiffs, about 400 homeowners whose homes were located in the upper White Oak Bayou watershed of Harris County, filed suit against the County, asserting a takings cause of action. Plaintiffs claim that the flooding of their homes was caused by the County’s approval of “unmitigated” upstream development, combined with a failure to fully implement the Pate Plan, a flood-control plan. The court of appeals affirmed the trial court's denial of the County's motion for summary judgment. The court concluded that, assuming all disputed facts in favor of the homeowners, the record is clear that the County never harbored a desire to cause flooding anywhere. In this case, assuming that a cause of the flooding was the affirmative act of approving private development, there indisputably were other causes: heavy rainfall, and, according to the homeowners themselves, the failure to fully implement the flood-control measures of the Pate Plan. The court concluded that the confluence of these circumstances does not give rise to a takings claim. Accordingly, the court reversed and rendered judgment dismissing the case. View "Harris Cnty. Flood Control Dist. v. Kerr" on Justia Law

After Randall Seger died while working on a hydraulic-lift drilling rig when it suddenly collapsed, his parents obtained a judgment against the drilling company. The drilling company then assigned its rights against the insurers to the parents, and the parents brought a Stowers action against the insurers. See G.A. Stowers Furniture Co. v. Am. Indem. Co. The court held that, because the evidence is legally insufficient to support a jury verdict to the contrary, Randall was a leased-in worker as a matter of law. In this case, plaintiffs' claimed loss was excluded from coverage under the commercial general liability (CGL) policy and the Stowers action fails as a result. The court did not reach the damages issue addressed by the court of appeals. Accordingly, the court affirmed the judgment, which reversed the trial court's judgment and rendered judgment that plaintiffs take nothing, but on different grounds. View "Seger v. Yorkshire Ins." on Justia Law

ERG, a Texas entity, filed suit against a Canadian entity and a Bermudian shareholder in Texas for tortious interference with its share purchase agreement. ERG also filed suit against the Bermudian owner of the Colombian oil and gas operations in Texas for fraud. The court held that when the Canadian entity sought to purchase shares of a Bermudian entity that owns Colombian assets from a Bermudian shareholder and did not intend to develop a Texas business, it did not purposefully avail itself of Texas’s jurisdiction. The court held, however, that Texas courts have specific - although not general - jurisdiction over the Bermudian owner of the Colombian oil and gas operations. In this case, the claims against the Bermudian owner turn on its Texas-based executives’ alleged misrepresentations in Texas to a Texas entity. While these claims alleging malfeasance stemming from the actions of the executives here, and of those to whom they gave marching orders, is relevant to the specific jurisdiction analysis, these contacts are insufficient to confer general jurisdiction over the Bermudian owner. Accordingly, the court affirmed the judgment. View "Searcy v. Parex Resources, inc." on Justia Law

After a burst of gas exploded out of a pipe and caused injury to Johannes Elmgren, a boilermaker for an independent contractor, he and his wife filed suit against Ineos and Jonathan Pavlovsky, an Ineos employee who the Elmgrens alleged was the “furnace maintenance team leader.” The court concluded that Chapter 95 of the Texas Civil Practice & Remedies Code applies to all categories of negligence claims, including those based on respondeat superior, but Chapter 95 does not apply to claims against an employee or agent of a property owner; plaintiffs in this case failed to present any evidence to trigger an exception to the protection Chapter 95 provides to Ineos; and thus the court: (1) affirmed the part of the court of appeals’ judgment affirming the trial court’s summary judgment on plaintiffs’ premises-liability claims against Ineos, (2) reversed the part of the court of appeals’ judgment reversing the trial court’s summary judgment on plaintiffs’ negligent-activity and negligent-undertaking claims against Ineos and rendered judgment in favor of Ineos on those claims, and affirmed the part of the court of appeals’ judgment reversing the trial court’s summary judgment on the claims against Pavlovsky and remanding those claims to the trial court. View "Ineos USA, LLC v. Elmgren" on Justia Law

Defendants are three nonresident private-equity fund limited partnerships and their general partner. The funds invested in a newly created Texas subsidiary that purchased a chain of Texas hospitals from a Texas company. Cornerstone, a Texas company allegedly in the market to purchase the hospitals, filed suit alleging that this conduct was tortious and subjects defendants to Texas’s jurisdiction with respect to claims arising out of that conduct. The court held that the trial court has personal jurisdiction over the Funds and the General Partner where the claims arise out of defendants' Texas contacts and where exercising personal jurisdiction over defendants comports with traditional notions of fair play and substantial justice. Accordingly, the court affirmed the judgment. View "Cornerstone Healthcare Grp. Holding v. Nautic Mgmt." on Justia Law