Justia Texas Supreme Court Opinion Summaries

The case involves a fatal accident that occurred at a private railroad crossing owned by Ezra Alderman Ranches, Inc. and operated by Union Pacific Railroad Company. Rolando Prado, Jr. died when his vehicle was struck by a Union Pacific train at the crossing. His family members (the Prados) sued both Union Pacific and Ezra Alderman Ranches, Inc. for negligence. The central issue before the Supreme Court of Texas was whether the evidence was sufficient to create a fact issue on whether the railroad crossing, which was protected by both a stop sign and a crossbuck sign, was "extra-hazardous" and whether the landowner knew it was "unreasonably dangerous."The court held that the evidence was insufficient to support a finding that the crossing was extra-hazardous. The court reasoned that the crossing had a stop sign in addition to the usual crossbuck sign, and anyone who actually stopped at the sign could clearly see a train coming from either direction. The expert testimony that suggested drivers would not stop at a particular stop sign because it "lacks credibility" did not establish that all reasonably prudent drivers would not, much less could not, stop at the sign.The court also held that there was no evidence to support a finding that the landowner, Ezra Alderman Ranches, Inc., had actual knowledge that the crossing was unreasonably dangerous. The court determined that the evidence indicated that the landowner knew of the high volume of traffic at the crossing, but it did not establish that the landowner had actual knowledge that the crossing was unreasonably dangerous.The court reversed the decision of the court of appeals and reinstated the judgment of the trial court in favor of Union Pacific and Ezra Alderman Ranches, Inc. View "UNION PACIFIC RAILROAD COMPANY v. PRADO" on Justia Law

The case in question was heard by the Supreme Court of Texas and revolved around the interpretation of the term "psychiatrist" as it applies to the involuntary civil commitment of individuals exhibiting signs of mental illness. The case involved a 34-year-old man, A.R.C., who had exhibited psychotic symptoms and delusional behavior. Two second-year psychiatry residents completed the required "certificates of medical examination for mental illness," as outlined in Tex. Health & Safety Code § 574.009(a). However, a question arose as to whether these residents could be considered psychiatrists under the statute.The Supreme Court of Texas ruled that these residents were indeed psychiatrists, reversing the lower court's judgment. The court determined that the residents, who were licensed under a physician-in-training program and were engaged in specialized psychiatric training, fell within the definition of a physician specializing in psychiatry. The court rejected the argument that only board-certified psychiatrists qualify under the statute, stating that physicians who specialize in psychiatry qualify as psychiatrists under § 574.009(a).The court emphasized that it is the judge, not the physician, who ultimately decides whether involuntary commitment is necessary or lawful. The court also noted that the legislature has the power to amend the qualifications for psychiatrists and other physicians as it sees fit, provided it adheres to the constitutional requirement of competent medical or psychiatric testimony.The Supreme Court of Texas remanded the case to the court of appeals for consideration of A.R.C.'s remaining challenges. View "IN RE A.R.C." on Justia Law

This case involves a dispute over the right to use a gravel crossing over a railroad track in Johnson County, Texas. The landowners, Nathan Albert and Chisholm Trail Redi-Mix, LLC, were granted an easement by necessity, an easement by estoppel, and a prescriptive easement by a jury, allowing them to cross the railroad tracks owned by the Fort Worth & Western Railroad Company (Western). The jury also found that the landowners did not trespass on the railroad’s property. The Court of Appeals reversed these findings, stating that the evidence was legally insufficient to support the jury’s easement findings and factually insufficient to support the trespass finding. The Supreme Court of Texas partially reversed the Court of Appeals' judgment. It held that while the evidence was legally insufficient to support the jury's findings of an easement by necessity and an easement by estoppel, it was legally sufficient to support the prescriptive easement. The Supreme Court of Texas remanded the case back to the Court of Appeals to consider unresolved issues involving the boundaries and permitted uses of the easement. The dispute started when the railroad company began sending notices to the landowners that they were trespassing on the railroad’s property by using the gravel crossing. Despite this, the gravel crossing had been used without issue for many years and had been referenced as a "private road" on local maps since the 1940s. View "ALBERT v. FORT WORTH & WESTERN RAILROAD COMPANY" on Justia Law

The Supreme Court of Texas evaluated a case in which a land development company, Bellpas, Inc., sought to detach property from one school district and annex it to another. According to the Texas Education Code, if the school boards of the affected districts disagree on the petition, the Commissioner of Education can resolve the issue in an administrative appeal. However, the Lampasas Independent School District (LISD) board neglected to approve or disapprove the petition, leading to a disagreement over whether the Commissioner of Education had jurisdiction over the administrative appeal.The Supreme Court of Texas held that the Commissioner of Education did have jurisdiction over the administrative appeal. The court reasoned that a school board "disapproves" a petition if it does not approve it within a reasonable time after a hearing, as per the plain reading of the Education Code. The court also concluded that the Commissioner did not lose jurisdiction by failing to issue a ruling within 180 days, as the statute's deadline is not jurisdictional.The case was returned to the Court of Appeals to resolve the appeal on its merits. The Supreme Court of Texas stressed that the delay in the administrative appeal process should not deprive the appellant of a decision on the merits of their petition and criticized the school board for refusing to make a decision, thus avoiding any ruling on the merits. View "MORATH v. LAMPASAS INDEPENDENT SCHOOL DISTRICT" on Justia Law

In June 2020, a local newspaper in Polk County published an article criticizing a local assistant district attorney, Tommy Coleman. The article claimed that Coleman had "assisted with the prosecution of Michael Morton" while he was a prosecutor in Williamson County. Michael Morton was wrongfully convicted in 1987 due to prosecutorial misconduct, a conviction that occurred before Coleman began practicing law. Morton was exonerated in 2011 after spending nearly 25 years in prison. The article specifically highlighted an instance during a post-conviction hearing where Coleman mocked requests for DNA testing of evidence that would eventually exonerate Morton. Coleman sued the newspaper and its author for defamation, arguing that the claim that he assisted in Morton's prosecution was false and defamatory.The Supreme Court of Texas held that the article's statement that Coleman "assisted with the prosecution of Michael Morton" was substantially true given Coleman’s public involvement in his office’s efforts to resist DNA testing of the evidence that exonerated Morton. The Court ruled that even if the article was not precise in its characterization of Coleman's role, the "gist" of the article - that Coleman supported the efforts to keep Morton behind bars by resisting DNA testing - was substantially true and therefore not actionably defamatory. As such, Coleman's claims were dismissed. View "POLK COUNTY PUBLISHING COMPANY v. COLEMAN" on Justia Law

This case involves a dispute between a homeowner, Mario Rodriguez, and his insurance company, Safeco Insurance Company of Indiana. After a tornado damaged Rodriguez's home, Safeco issued a payment of $27,449.88, which Rodriguez accepted. Rodriguez's counsel then informed Safeco that it owed an additional $29,500 and threatened to sue. Rodriguez sued Safeco, bringing several claims, including breach of contract and statutory claims under the Insurance Code. Safeco invoked the insurance policy’s appraisal provision and subsequently issued a check to Rodriguez for $32,447.73, which it viewed as full payment of the appraisal amount due under the policy. Safeco also paid an additional $9,458.40, which it claimed would cover any interest possibly owed on the appraised amount.The Supreme Court of Texas was asked to answer a certified question from the United States Court of Appeals for the Fifth Circuit: “In an action under Chapter 542A of the Texas Prompt Payment of Claims Act, does an insurer’s payment of the full appraisal award plus any possible statutory interest preclude recovery of attorney’s fees?” The Supreme Court of Texas held that the answer is yes. When an insurer has fully discharged its obligations under the policy by voluntarily paying the appraised amount, plus any statutory interest, in compliance with the policy’s appraisal provisions, section 542A.007 of the Insurance Code prohibits an award of attorney’s fees. This is because there is no remaining “amount to be awarded in the judgment to the claimant for the claimant’s claim under the insurance policy,” which means no attorney’s fees are available under section 542A.007(a)(3)’s formula. View "RODRIGUEZ v. SAFECO INSURANCE COMPANY OF INDIANA" on Justia Law

In Houston, Texas, a nurse was struck and killed by a driver while crossing the public street next to the hospital where she worked. The nurse's family filed a suit against the hospital, arguing that the hospital had a duty to make the adjacent public road safer due to the layout of its exit and parking lot, which they claimed created a situation in which injury to others was foreseeable. The Supreme Court of Texas ruled that the hospital had a limited duty as a premises occupier based on its control over certain parts of the adjacent public right-of-way. However, the court found no evidence that any dangerous condition the hospital controlled in the right-of-way caused the nurse’s harm. The court rejected the lower courts' ruling that there was a case-specific duty for the hospital to make the road safer. The court reversed the judgment of the lower courts, rendering a take-nothing judgment in favor of the hospital. View "HNMC, INC. v. CHAN" on Justia Law

The Supreme Court of Texas considered a medical negligence case where a 13-year-old girl, Raynee Dunnick, was bitten by a rattlesnake and was treated by Dr. Kristy Marsillo at a local hospital. The hospital had a specific guideline for snakebite treatment, which was followed by Dr. Marsillo. This guideline recommends administering antivenom, a treatment for snakebite, only when certain clinical parameters are met. According to the guideline, the risk of side effects from the antivenom should also be considered.Raynee and her parents sued Dr. Marsillo, claiming that her adherence to the guidelines and her decision not to immediately administer the antivenom upon Raynee's arrival at the hospital was negligent and resulted in Raynee's pain, suffering, impairment, and disfigurement. The trial court granted Dr. Marsillo's motion for summary judgment on the grounds of no-evidence of breach of duty and causation. The court of appeals reversed this decision, but Dr. Marsillo appealed to the Supreme Court of Texas.In its decision, the Supreme Court of Texas held that under section 74.153(a) of the Civil Practice and Remedies Code, a heightened standard of proof is required for a patient's negligence claim against a physician for injuries arising out of the provision of emergency medical care. The claimant must show by a preponderance of the evidence that the physician acted with willful and wanton negligence, which is at least equivalent to gross negligence.The court found that the evidence presented by Raynee did not meet this standard. Specifically, the court found that the expert affidavit provided by Raynee was conclusory and did not adequately explain why the guidelines should have been disregarded or why doing so would have posed an extreme degree of risk to Raynee. Therefore, the court reversed the court of appeals’ judgment and reinstated the trial court’s summary judgment in favor of Dr. Marsillo. View "MARSILLO v. DUNNICK" on Justia Law

The Supreme Court of Texas handled a case in which a nurse claimed her employer, Scott & White Memorial Hospital, wrongfully terminated her employment in retaliation for reporting potential child abuse or neglect to the Texas Child Protective Services (CPS), which is considered a protected conduct under Section 261.110(b) of the Texas Family Code.The nurse, Dawn Thompson, had previously received two written reprimands for violating the hospital's personal-conduct policy. On the third occasion, she disclosed a child patient's protected health information to a school nurse without the parents' authorization. This was considered by the hospital as a violation of the Health Insurance Portability and Accountability Act (HIPAA) and a breach of the patient's rights. Consequently, Thompson was terminated.Thompson filed a lawsuit against the hospital, asserting that her termination was in violation of Family Code Section 261.110(b), which protects professionals who report child abuse or neglect in good faith from adverse employment actions.The Supreme Court of Texas ruled that Section 261.110 imposes a "but-for causation" requirement, which means that the protected conduct must be such that without it, the adverse employment action would not have occurred when it did. In this case, the court found that Thompson would have been terminated when she was due to her HIPAA violation, regardless of her report to CPS. Therefore, the court rejected Thompson's retaliation claim and reinstated the trial court's summary judgment in favor of the hospital. View "SCOTT & WHITE MEMORIAL HOSPITAL v. THOMPSON" on Justia Law

In Texas, the District Attorney for the 38th Judicial District, Christina Mitchell Busbee, objected to the sale of a property that was purchased with the District's forfeiture funds and was legally owned by Medina County. The District Attorney argued that the County could not sell the property without her consent and that she was entitled to the sale proceeds. The trial court and the court of appeals ruled that the District Attorney did not have standing to make these claims because the relevant statute, Chapter 59, authorizes only the Attorney General to enforce its terms. The Supreme Court of Texas disagreed, holding that the question of whether the District Attorney was authorized to sue under Chapter 59 did not pertain to her constitutional standing to sue, but rather to the merits of her claims. The Court concluded that the District Attorney did have constitutional standing to sue because she had alleged a concrete injury traceable to the County's conduct and redressable by court order. The case was remanded back to the trial court to consider the County's additional jurisdictional challenges. View "BUSBEE v. COUNTY OF MEDINA, TEXAS" on Justia Law