Justia Texas Supreme Court Opinion Summaries

Shortly after the City of Houston enacted a drainage-free ordinance, Houston Belt & Terminal Railway, BNSF Railway, and Union Pacific Railway (collectively, the Railroads) received notices of proposed charges for their properties in Houston. Daniel Krueger, the City’s Director of Public Works and Engineering, determined that the properties were “benefitted” and thus subject to drainage charges and determined that the Railroads should pay roughly $3 million based on their benefitted properties’ “impervious surface” area. The Railroads filed suit against the City and Krueger in his official capacity, alleging ultra vires claims against Krueger and seeking prospective injunctive relief. The trial court sustained the City’s plea to the jurisdiction as to the Railroads’ ultra vires claims based on governmental immunity. The court of appeals affirmed in part and reversed in part, concluding that the Railroads pleaded a viable ultra vires claim challenging Krueger’s determination that their properties were benefitted but that the railroads’ challenge to Krueger’s “impervious surface” determination did not fall within the ultra vires exception. The Supreme Court reversed in part, holding that the Railroads’ pleadings affirmatively alleged that Krueger acted “without legal authority” in both his “benefitted property” and “impervious surface” determinations, and thus the pleadings alleged viable ultra claims as to each. View "Houston Belt & Terminal Ry. Co. v. City of Houston" on Justia Law

Caffe Ribs, Inc. (Caffe) purchased condemned property that was contaminated. After the property was placed into the Texas Commission on Environmental Quality’s (TCEQ) Voluntary Cleanup Program, two of the property’s previous owners (Previous Owners) began remediation. The TCEQ requested four additional groundwater monitoring wells, but the Previous Owners were not able to comply with the request due in part to the State’s impending condemnation. The State then initiated statutory condemnation proceedings against Caffe. For reasons not relevant to this appeal, the Court of Appeals remanded the case for a new trial. At retrial, the State presented testimony that it would take eight years of cleanup to render the property marketable and that the property’s value should be substantially discounted on that basis. Caffe sought to offer testimony that the State’s condemnation project delayed the property’s cleanup, but the trial court excluded the testimony. The jury determined the value of the property to be just under $5 million. The court of appeals affirmed, concluding that the exclusion of Caffe’s proffered testimony was harmless. The Supreme Court reversed, holding that the trial court abused its discretion in excluding evidence concerning the State’s role in delaying the condemned property’s environmental cleanup. Remanded for a new trial. View "Caffe Ribs, Inc. v. State" on Justia Law

The nearly identical wills of Vencie Beard and Melba Beard contained a provision stating that if both the husband and wife died in a “common disaster or under circumstances making it impossible to determine [who] died first,” the testator bequeathed specified cash amounts to nine individuals. Melba died at 8:59 p.m. and Vencie died at 10:55 p.m. on the same night after Vencie shot and killed Mebla before taking his own life. The trial court determined that the Beards died in a common disaster and that the Simultaneous Death Act (SDA) was incorporated into the Beards’ wills. The court of appeals affirmed. The Supreme Court reversed, holding that the Beards’ deaths did not trigger the common-disaster provisions in their wills. View "Stephens v. Beard" on Justia Law

The nearly identical wills of Vencie Beard and Melba Beard contained a provision stating that if both the husband and wife died in a “common disaster or under circumstances making it impossible to determine [who] died first,” the testator bequeathed specified cash amounts to nine individuals. Melba died at 8:59 p.m. and Vencie died at 10:55 p.m. on the same night after Vencie shot and killed Mebla before taking his own life. The trial court determined that the Beards died in a common disaster and that the Simultaneous Death Act (SDA) was incorporated into the Beards’ wills. The court of appeals affirmed. The Supreme Court reversed, holding that the Beards’ deaths did not trigger the common-disaster provisions in their wills. View "Stephens v. Beard" on Justia Law

Michael McMillen, an attorney who served as Deputy Counsel for the Texas Health and Human Services Commission’s Office of the Inspector General (OIG), prepared a memorandum concluding that the Commission’s practice of obtaining payments from certain recipients of Medicaid benefits lacked legal justification. McMillen submitted the memorandum to the Deputy Inspector General for the Commission and asserted that he made a noter report to the head of the OIG Internal Affairs Division and to the Commission’s Executive Commissioner. McMiller was later terminated. McMillen sued the Commission and its Executive Commissioner under the Whistleblower Act, alleging retaliatory discharge. Defendants filed a plea to the jurisdiction, arguing that McMillen’s allegations were not sufficient to invoke the Act and waive immunity. The trial court denied the plea. The court of appeals reversed, concluding that McMillen did not report to an appropriate law-enforcement authority under the Act. The Supreme Court reversed, holding that the reported-to persons in this case were an appropriate law-enforcement authority under the Act. Remanded. View "McMillen v. Tex. Health & Human Servs. Comm’n" on Justia Law

When Mother and Father divorced, the decree gave Mother the exclusive right to determine the primary residence of the couple’s two sons and ordered Father to pay monthly child support. After Mother moved to another city with the children, Father filed a motion to modify the divorce decree to obtain the right to determine the children’s residence and to reduce his child support. The trial court granted Father’s petition. After the trial court’s plenary jurisdiction had expired, Mother filed a motion to reopen and vacate order, arguing that she had not been given notice of Father’s motion to modify because she did not live at the address where the citation was posted. The trial court denied the motion. The court of appeals dismissed Mother’s appeal for want of jurisdiction, concluding that Mother’s motion did not extend the trial court’s plenary jurisdiction and post-judgment deadlines to run from the date she received notice of the trial court’s order because it was not captioned a motion under Tex. R. Civ. P. 306a. The Supreme Court reversed, holding that justice plainly required the trial court and court of appeals to treat Mother’s motion as extending post-judgment deadlines and that Mother's appeal was timely filed. Remanded. View "In re Interest of J.Z.P." on Justia Law

Petitioner sued Respondent, her employer, to recover damages for an injury she received during the course of her employment. Respondent moved to compel arbitration based on its employee handbook. Petitioner opposed arbitration, arguing that the arbitration agreement was unconscionable and illusory. The trial court denied the motion, basing its ruling on only some of Petitioner’s unconscionability arguments and without discussing her remaining arguments. Respondent filed an interlocutory appeal. The court of appeals reversed, thus rejecting the trial court’s express grounds in its ruling. Petitioner petitioned for review, arguing that she raised other grounds to deny arbitration that the court of appeals did not address. The Supreme Court granted Petitioner’s petition and reversed, holding that the could of appeals could not order arbitration without addressing all of Petitioner’s arguments or remanding the case to the trial court to address them. View "Cardwell v. Whataburger Restaurants LLC" on Justia Law

Four oil and gas leases were assigned in one instrument. At issue in this case was how to calculate a production payment reserved in the assignment of the four leaseholds. When two of the leases terminated, the payor asserted that the production payment should be reduced to reflect the loss of the underlying mineral-lease interests. The payee responded by asserting that the production payment burdened the four leases jointly and that the assignment included authorization to adjust the payment. The trial court construed the assignment as allowing for the production payment’s adjustment based on the expiration of an underlying lease. The court of appeals reversed, concluding that the production payment could not be reduced because the assignment failed to include “express language providing for a piecemeal reduction of the production payment.” The Supreme Court reversed, holding that the trial court rendered the correct judgment in this case. View "Apache Deepwater, LLC v. McDaniel Partners, Ltd." on Justia Law

Petitioners in this case were Mexican citizens who broadcast television programs on over-the-air signals that originated in Mexico but traveled into parts of Texas. Respondents were residents of Texas who alleged that Petitioners defamed them in some of those television programs. Petitioners filed special appearances challenging the trial court’s jurisdiction over them. The trial court denied the special appearances. In an interlocutory appeal, the court of appeals affirmed. The Supreme Court affirmed, holding that the evidence supported the trial court’s conclusion that Petitioners had minimum contacts with Texas and that the exercise of specific personal jurisdiction over Petitioners will not offend traditional notions of fair play and substantial justice. View "TV Azteca, S.A.B. de C.V. v. Ruiz" on Justia Law

In general, an overriding royalty on oil and gas production must bear its share of postproduction costs unless the parties agree otherwise. The Hyder family leased 948 mineral acres to Chespeake Exploration, LLC. The Hyders and Chesapeake agreed that the overriding royalty in the parties’ lease was free of production costs but disputed whether it was also free of postproduction costs. The trial court rendered judgment for the Hyders, awarding them postproduction costs that Chesapeake wrongfully deducted from their overriding royalty. The court of appeals affirmed. The Supreme Court affirmed, holding that the parties’ lease clearly freed the overriding royalty of postproduction costs. View "Chesapeake Exploration, LLC v. Hyder" on Justia Law