Justia Texas Supreme Court Opinion Summaries

Steven Phillips was convicted of and pled guilty to several crimes. A DNA test conducted several years later excluded Phillips as the perpetrator. The trial court granted habeas relief. Thereafter, Phillips applied to the Comptroller for wrongful imprisonment compensation under the Tim Cole Act (“the Act”). The Comptroller found that Phillips was due $2 million for the time he was incarcerated. Phillips also requested compensation for child support he had failed to pay. A 1978 Arkansas divorce decree ordered Phillips to pay Cheryl Macumber child support. In 2013, Macumber sued Phillips in Texas to register and enforce the Arkansas divorce decree. The trial court rendered judgment (“the Enforcement Judgment”) for Macumber, finding she was entitled to $304,861. Phillips requested that the Comptroller pay child support compensation based on the amount awarded by the Enforcement Judgment. The Comptroller concluded that compensation owed under the Act was $25,125. Phillips petitioned for mandamus relief. The Supreme Court granted conditional relief, holding (1) the Comptroller is not bound by a court’s judgment in a child support enforcement proceeding; (2) the Comptroller’s determinations are subject to review by the Supreme Court; and (3) in this case, the Comptroller is directed to recalculate the compensation owed to Phillips under section 103.052(1)(2) of the Act. View "In re Phillips" on Justia Law

More than half of the State’s school districts and various entities and individuals brought this school funding challenge arguing, among other things, that the current school finance system violates the adequacy and suitability requirements of Tex. Const. art. VII, 1. The trial court declared the school system constitutionally inadequate, unsuitable and financially inefficient in violation of Article VII, section 1, that the system is unconstitutional as a statewide ad valorem tax in violation of Tex. Const. art. VIII, 1(e), and that the system does not meet constitutional adequacy and suitability requirements for two subgroups of students. The Supreme Court reversed, holding that the current school funding regime meets minimum constitutional requirements, despite its imperfections. View "Morath v. Texas Taxpayer & Student Fairness Coalition" on Justia Law

After Tenant moved into her apartment, her apartment and several adjoining units were severely damaged in a fire that originated in Tenant’s clothes dryer. Insurer paid Landlord’s insurance claim and then sued Tenant for negligence and breach of the Apartment Lease Contract. The jury found that Tenant breached the lease agreement and awarded $93,498 in actual damages and attorney’s fees from Insurer. Tenant filed a motion for judgment notwithstanding the verdict, asserting several grounds for avoiding enforcement of the contract. The trial court granted Tenant’s motion and rendered a take-nothing judgment. The court of appeals affirmed, concluding that the residential-lease provision imposing liability on Tenant for property losses resulting from “any other cause not due to [the landlord’s] negligence or fault” was void and unenforceable because it broadly and unambiguously shifted liability for repairs beyond legislatively authorized bounds. The Supreme Court affirmed in part and reversed in part, holding (1) the court of appeals properly rejected Tenant’s ambiguity defense; but (2) the court of appeals erred in invalidating the lease provision on public-policy grounds. Remanded. View "Philadelphia Indem. Ins. Co. v. White" on Justia Law

At issue in this case was amendments to a Houston air-quality ordinance (the Ordinance). BCCA Appeal Group filed suit seeking a declaratory judgment that Ordinance was invalid and unenforceable under the Texas Clean Air Act, the Water Code, and the Texas Constitution. The trial court granted summary judgment for BCCA, concluding that the Ordinance violated the Texas Constitution and was preempted by the Act, and enjoined the City from enforcing the Ordinance. The court of appeals reversed, concluding that the Ordinance was consistent with the Act and the Water Code and did not violate the nondelegation doctrine of the Texas Constitution by incorporating Texas Commission on Environmental Quality (TCEQ) rules in such a way as to include future amendments. The Supreme Court reversed in part and affirmed in part, holding (1) the Ordinance’s enforcement provisions and registration requirement are preempted and therefore unenforceable; but (2) the Ordinance’s incorporation of TCEQ rules does not violate the nondelegation doctrine of the Texas Constitution. View "BCCA Appeal Group, Inc. v. City of Houston" on Justia Law

Plaintiff began working for BNSF Railway Company’s predecessor-in-interest in 1974 and, approximately five years later, began to ride on locomotives as a breakman. While riding on the locomotives, Plaintiff alleged that he suffered long-term vibratory exposure resulting in an occupational injury. Plaintiff sued BNSF under the Federal Employers’ Liability Act (FELA) and the Locomotive Inspection Act (LIA) to recover damages. After a jury trial, the trial court rendered judgment awarding Plaintiff $1.9 million in costs and damages. BNSF appealed, arguing that there was no evidence to support the jury’s finding that Plaintiff’s lawsuit was timely filed. The court of appeals affirmed. The Supreme Court reversed and rendered judgment that Plaintiff take nothing, holding that Plaintiff’s claim was time-barred. View "BNSF Railway Co. v. Phillips" on Justia Law

Plaintiff entered into an agreement with Defendant, a municipality, to install pollution control equipment at a power plant. Plaintiff fully performed the agreement, but Defendant withheld the retainage from Plaintiff. Consequently, Plaintiff filed a breach of contract action against Defendant and requested reasonable and necessary attorney’s fees, costs, and interest. Defendant filed a plea to the jurisdiction seeking dismissal of Plaintiff’s claims for attorney’s fees for lack of jurisdiction, arguing that attorney’s fees were outside the scope of statutorily-waived immunity as Tex. Local Gov’t Code 271.152 was written at the time of the agreement. In response, Plaintiff argued that Defendant had no immunity from suit because it was performing a proprietary function in its dealings with Plaintiff. The trial court granted Defendant’s plea to the jurisdiction and dismissed Plaintiff’s claims for attorney’s fees. The court of appeals affirmed. The Supreme Court reversed, holding (1) Defendant was performing a proprietary function and, therefore, was not immune from suit based on governmental immunity; and (2) a claim for attorney’s fees arising from those proprietary actions does not implicate governmental immunity. View "Wheelabrator Air Pollution Control, Inc. v. City of San Antonio" on Justia Law

The Texas Tax Code provides that “only the net gain” from the sale of investments should be included in a key component of the statutory franchise-tax formula. In implementing Texas’ statutory franchise-tax liability scheme, the state comptroller adopted a rule requiring businesses to include net gains or net losses. Hallmark Marketing Company filed a franchise-tax protest suit against the state comptroller seeking a refund of more than $200,000 in taxes it paid, arguing that the comptroller’s rule conflicts with the very statute it purports to enforce. The trial court and court of appeals ruled in favor of the comptroller. The Supreme Court reversed, holding that Tex. Tax Code 171.105(b) does not require Hallmark to include a net loss from the sale of investments. Remanded. View "Hallmark Marketing Co., LLC v. Hegar" on Justia Law

Plaintiff sued Defendant for defamation. The trial court dismissed the suit under the Texas Citizens Participation Act, which provides for the award of attorney’s fees and expenses, as well as sanctions “sufficient to deter” future similar actions. The trial court granted a portion of the attorney’s fees and expenses requested by Defendant but declined to award sanctions. The court of appeals affirmed the trial court’s award of attorney’s fees and expenses but remanded for the trial court to reconsider its decision to deny sanctions. The Supreme Court reversed, holding that the courts below used the wrong standard in determining the attorney’s fees portion of the award. Remanded to the trial court for its determination of “reasonable attorney’s fees” under the appropriate standard. View "Sullivan v. Abraham" on Justia Law

Plaintiff, a public official, sued Defendants, a politically oriented blog and its executive director, for libel. The trial court dismissed the action under the Texas Citizens Participation Act, concluding that Plaintiff had not met his burden of proving that Defendant published the alleged falsehood with “actual malice.” Plaintiff appealed, arguing that actual malice was not an element of his claim because his status in relation to the defamation was more that of a private individual than a public official. The court of appeals agreed with Plaintiff and reversed the judgment. The Supreme Court reversed, holding that actual malice was an element of Plaintiff’s defamation claim. Remanded. View "Greer v. Abraham" on Justia Law

In In re P.M., the Supreme Court concluded that, in government-initiated parental rights termination proceedings, the statutory right of indigent parents to counsel endures until all appeals are exhausted. In this case, the trial court terminated the parental rights of C.S.F. The court of appeals affirmed. Acting pro se and outside the time for filing a petition for review, C.S.F. filed a motion in the Supreme Court seeking an extension of time and a hand-written indigency affidavit. The Supreme Court referred the case to the trial court for appointment of counsel to represent C.S.F. in the Supreme Court, holding that C.S.F. should be able to pursue any argument regarding her case with the assistance of new counsel. View "C.S.F. v. Dep’t of Family & Protective Servs." on Justia Law