Justia Texas Supreme Court Opinion Summaries

In 2008, the Railroad Commission of Texas issued orders to plug a number of inactive offshore wells operated in the Gulf of Mexico. Gulf Energy Exploration Corporation was the lessee of the offshore area that included one of wells subject to the plugging order. The Commission and Gulf Energy reached an agreement that the Commissioner would delay plugging this well. A few months later Gulf Energy discovered that the well was plugged. Gulf Energy sued the Commission with legislative permission. The jury returned a favorable verdict on Gulf Energy’s negligence and breach-of-contract claims. The court of appeals affirmed. The Supreme Court reversed, holding (1) the trial court erred in refusing to submit a jury question on a statutory good-faith defense; and (2) a question of fact existed as to whether the Commission and Gulf Energy entered into a binding contract before the well was plugged. Remanded for a new trial. View "R.R. Comm’n of Texas v. Gulf Energy Exploration Corp." on Justia Law

Middle school and high school cheerleaders, through their parents, sued Kountze Independent School District after the District prohibited them from displaying banners at school-sponsored events containing religious messages or signs. The District filed a plea to the jurisdiction, asserting mootness in light of its subsequent adoption of a resolution providing that the District was not required to prohibit religious messages on school banners. The trial court denied the District’s plea. The court of appeals reversed, concluding that Plaintiffs’ claims for declaratory and injunctive relief were moot because the District voluntarily discontinued its prohibition on the display of banners containing religious messages or signs. The Supreme Court reversed, holding that because the resolution only states that the District is not required to prohibit the cheerleaders from displaying religious messages on school banners and reserves to the District discretion in regulating those banners, this case was not moot, as the challenged conduct might reasonably be expected to recur. Remanded. View "Matthews v. Kountze Indep. Sch. Dist." on Justia Law

Plaintiff sued Defendants, attorneys Eric Turton and Oscar Gonzalez and the Law Office of Oscar C. Gonzalez, alleging that they misappropriated $75,000 in trust funds that Turton received after settling a case on Plaintiff’s behalf. The jury found that all three defendants were engaged in a joint enterprise and a joint venture with respect to Plaintiff’s case and committed various torts in relation to Plaintiff. In response to a proportionate-responsibility question, the jury assigned forty percent to Turton, thirty percent to Gonzalez, and thirty percent to the Law Office. The trial court entered judgment holding all three defendants jointly and severally liable for actual damages, pre-judgment interest, additional Texas Deceptive Trade Practices and Consumer Protection Act damages, and attorney’s fees. Gonzalez and the Law Office appealed. The court of appeals concluded that Plaintiff could only recover for professional negligence, which amounted to $77,500 in actual damages. The court’s opinion did not address the jury’s proportionate-responsibility findings but nonetheless applied those findings in its judgment, ordering Gonzalez and the Law Firm to each pay Sloan $23,250. The Supreme Court reversed, holding that the court of appeals erred by failing to address the sufficiency of the evidence of a joint enterprise or joint venture or the legal implications of those findings. Remanded. View "Sloan v. Law Office of Oscar C. Gonzalez, Inc." on Justia Law

J&D Towing, LLC, a towing company, owned only one tow truck that was rendered a total loss when a negligent motorist collided with the truck. J&D filed a claim with American Alternative Insurance Corporation (AAIC) under an underinsured-motorist policy issued by AAIC requesting compensation for the loss of use of the truck. AAIC denied the claim. Thereafter, J&D sued AAIC seeking loss-of-use damages. The trial court entered judgment in favor of J&D. The court of appeals reversed, concluding that Texas law allows loss-of-use damages for partial destruction but not for total destruction of personal property. The Supreme Court reversed, holding that Texas law permits loss-of-use damages in total-destruction cases. View "J&D Towing, LLC v. Am. Alternative Ins. Corp." on Justia Law

Ray Fischer transferred his business assets to CTMI, LLC pursuant to a written asset-purchase agreement. CTMI later filed a second amended petition alleging that portions of the asset-purchase agreement were unenforceable “agreements to agree.” The trial court entered judgment in favor of Fischer. The court of appeals reversed and rendered judgment that the disputed portion of CTMI’s payment obligations was an unenforceable agreement to agree. The Supreme Court reversed, holding that the payment provision at issue was enforceable because its material terms were sufficiently definite to enable a court to determine CTMI’s obligation and provide a remedy for its breach. View "Fischer v. CTMI, LLC" on Justia Law

In 2006, Jason Jenkins was injured while using an acid-addition system at a chemical plant. The acid-addition was added to the plant in 1992 by Occidental Chemical Corporation. Occidental sold the plant to Equistar chemicals, L.P., Jenkins’s employer, in 1998. Jenkins sued Occidental, among other defendants, alleging that Occidental’s negligent design of the acid-addition system caused his injuries. Occidental affirmatively pled two statutes of repose. After a jury trial, the trial court rendered judgment that Jenkins take nothing, concluding that the verdict supported at least one of Occidental’s repose defenses. The court of appeals reversed, concluding that Jenkins’s claim was based on Occidental’s negligent design of the acid-addition system, a theory that survived Occidental’s sale of the property and continued independently of any premises-liability claim. The Supreme Court reversed, holding (1) a claim against a previous owner for injury allegedly caused by a dangerous condition of real property is a premises-liability claim, regardless of the previous property owner’s role in creating the condition; and (2) because the previous owner sold the property several years before Plaintiff’s accident and did not otherwise owe Plaintiff a duty of care, the court of appeals erred in holding Occidental liable for the dangerous condition and Jenkins’s injury. View "Occidential Chemical Corp. v. Jenkins" on Justia Law

U.S. Metals, Inc. sold ExxonMobil Corp. approximately 350 flanges for use in constructing diesel refinery processing units. In post-installation testing, several flanges leaked, and ExxonMobil decided it was necessary to replace them to avoid the risk of fire and explosion. ExxonMobil sued U.S. Metals for the cost of replacing the flanges and damages for the lost use of the diesel units during the process. U.S. Metal settled with ExxonMobil and then claimed indemnification from its commercial general liability (CGL) insurer, Liberty Mutual Group, Inc., for the amount paid. Liberty Mutual denied coverage. U.S. Metals sued in federal district court to determine its right to a defense and indemnity under the policy. Four questions were certified to the Supreme Court by the United States Court of Appeals for the Fifth Circuit. The Court concluded that the CGL does not cover most of the damages claimed and answered the circuit court’s questions accordingly. View "U.S. Metals, Inc. v. Liberty Mut. Group, Inc." on Justia Law

Plaintiff was injured in an automobile accident that occurred when a Texas Department of Public Safety (DPS) trooper ran a red light while pursuing a reckless driver. Plaintiff filed suit against DPS, relying on the Texas Tort Claims Act’s sovereign-immunity waiver. DPS filed a combined motion for summary judgment and plea to the jurisdiction, asserting that it retained immunity from suit based on the trooper’s official immunity and the emergency-response exception to the Tort Claims Act’s immunity waiver. The trial court denied DPS’s motion and plea. The court of appeals affirmed, concluding, inter alia, that DPS failed conclusively to establish the good-faith element of its official-immunity defense, and DPS’s summary judgment was incompetent to establish good faith because it failed to address whether the trooper considered alternative courses of action. The Supreme Court reversed, holding that the court of appeals applied an inaccurate good-faith standard and erred in concluding that DPS failed to adduce evidence addressing alternatives to pursuit. Remanded. View "Texas Dep’t of Pub. Safety v. Bonilla" on Justia Law

Plaintiff sued BNSF Railway Company, his employer, under the Federal Employers’ Liability Act and the Locomotive Inspection Act to recover damages for a latent occupational injury. After a jury trial, the trial court rendered judgment awarding Plaintiff $1.9 million in costs and damages. BNSF appealed, arguing that Plaintiff’s lawsuit was untimely. The court of appeals affirmed, concluding that because there was conflicting evidence in the record concerning when the injury occurred, the jury was entitled to weigh that evidence and reach its finding that Plaintiff’s lawsuit was timely filed. The Supreme Court reversed and rendered judgment that Plaintiff take nothing, holding that no evidence supported the jury’s finding that Plaintiff timely filed his lawsuit. View "BNSF Ry. Co. v. Phillips" on Justia Law

Plaintiff sued Hospital, alleging that she was injured when she slipped on water on the floor. Hospital filed a motion to dismiss, asserting that Plaintiff’s claim was a health care liability claim (HCLC), and Plaintiff failed to serve an expert report as required by the Texas Medical Liability Act. The trial court denied Hospital’s motion. The court of appeals reversed, concluding that because Plaintiff’s claim was based on an alleged departure from accepted standards of safety, it was an HCLC. The Supreme Court reversed, holding that no substantive nexus was shown to exist between the safety standards Plaintiff alleged Hospital violated the the provision of health care, and therefore, Plaintiff’s claim was not a health care liability claim. View "Galvan v. Memorial Hermann Hosp. Sys." on Justia Law