Justia Texas Supreme Court Opinion Summaries

Political parties may apply to the Secretary of State for state funds to reimburse expenses connected with administering primary elections. After Wendy Davis was certified as the Democratic nominee for State Senate District 10 in the primary election, Davis’s Republican opponent sued to remove Davis from the general election ballot. The challenge failed, and Davis prevailed in the general election. The state and county Democratic Party chairpersons subsequently applied for reimbursement of attorney’s fees related to defending the challenge to Davis’s candidacy. The Secretary of State declined to reimburse the legal expenses to the Democratic Party because the party incurred those expenses after the primary election and in connection with the general election. The district court upheld the Secretary’s decision. The Court of Appeals reversed, concluding that the legal expenses were plainly connected to the primary election because they were based on Davis’s alleged constitutional ineligibility to appear on the primary election ballot. The Supreme Court reversed, holding that the Secretary did not abuse his discretion in denying the requested reimbursement from the primary election fund, as the Secretary is not obligated to reimburse a political party for legal expenses incurred in defending its nominee’s right to appear on the general-election ballot. View "Cascos v. Tarrant County Democratic Party" on Justia Law

Plaintiff, a visitor at Hospital, fell when she slipped on a floor mat in the hospital lobby. Plaintiff sued Hospital on a premises liability theory. Hospital asserted that Plaintiff’s claim was a health care liability claim (HCLC) under the Texas Medical Liability Act, and therefore, the claim must be dismissed because Plaintiff did not serve an expert report as required by the Texas Medical Liability Act. The trial court denied Hospital’s motion to dismiss. The Court of Appeals reversed, concluding that the floor care of the hospital lobby had an indirect relationship to the provision of health care that was sufficient to satisfy the safety prong of the Act, and therefore, Plaintiff’s claim was an HCLC. The Supreme Court reversed and remanded for further proceedings, holding that the record did not reflect a substantive nexus between the safety standards Plaintiff claimed Hospital violated and Hospital’s provision of health care. View "Reddic v. E. Texas Med. Ctr. Reg’l Health Care Sys." on Justia Law

Kachina Pipeline Co., a pipeline operator, and Michael Lillis, a natural-gas producer, entered into a Gas Purchase Agreement. Kachina bought, transported, and resold Lillis’s gas according to the Agreement. Lillis later entered into a separate purchase agreement and constructed his own pipeline to one of Davis Gas Processing’s plants. Thereafter, Lillis sued Kachina, asserting that Kachina breached the Agreement by deducting the costs of compression that occurred after he delivered the gas to Kachina. Lillis also brought a fraud claim, asserting that Kachina represented it would release him from the Agreement. Kachina counterclaimed for breach of the Agreement and seeking declarations that it had the right to deduct compression charges under the Agreement. The trial court granted summary judgment for Kachina, declaring that the Agreement entitled Kachina to deduct the costs of compression from its payments to Lillis and that the Agreement gave Kachina the option to extend the arrangement for an additional five-year term. The court of appeals reversed, concluding that the agreement unambiguously allowed neither the disputed deductions nor a five-year extension. The Supreme Court affirmed, holding that the Agreement did not allow Kachine to deduct compression costs or support a five-year extension. View "Kachina Pipeline Co., Inc. v. Lillis" on Justia Law

Plaintiff, a spectator at a youth softball game was injured in a trip-and-fall accident while exiting a baseball complex in a City park. Plaintiff filed a premises-liability lawsuit against the City, alleging that the City violated its duty of ordinary care by creating an unreasonable risk of harm and failing to provide a safe walkway passage. The City filed a plea to the plea to the jurisdiction asserting that it retained its immunity from suit under the recreational use statute, which raises the liability standard required to trigger the Texas Tort Claims Act’s immunity waiver in premises-defect cases involving lands opened to the public for “recreation.” The trial court denied the plea. The court of appeals reversed, concluding that spectating at a sporting event constitutes recreation. The Supreme Court reversed, holding that spectating at a competitive-sporting event is not “recreation” under the recreational use statute. Remanded. View "Lawson v. City of Diboll" on Justia Law

After Ginger Weatherspoon was fired from her position as an assistant attorney general at the Office of the Attorney General (OAG), Weatherspoon sued the OAG under the Whistleblower Act. The OAG filed a plea to the jurisdiction, arguing that Weatherspoon’s allegations were not sufficient to invoke the Act and waive the state entity’s immunity from suit for retaliatory discharge. The trial court denied the OAG’s plea. The court of appeals affirmed. The Supreme Court granted the OAG’s petition for review, reversed the court of appeals’ judgment, and dismissed the case, holding that Weatherspoon could not show that her reports met the Act’s requirements, and therefore, the OAG remained immune from suit. View "Office of Attorney Gen. v. Weatherspoon" on Justia Law

In 2004, Employee was working for Employer when she fell, injuring her left knee and back. In 2009, Employee filed a claim for lifetime income benefits (LIBs) pursuant to section 408.161 of the Texas Workers’ Compensation Act claiming that her 2004 injury caused the total loss of use of both her feet at or above the ankle and that the loss of use was permanent. A hearing officer with the Division of Workers’ Compensation determined that Employee was not entitled to LIBs. The district court reversed and awarded LIBs. The court of appeals affirmed. The Supreme Court reversed and rendered judgment denying Employee’s claim for LIBs, concluding that the court of appeals erred in determining that the evidence was sufficient to support the trial court’s judgment. View "Dallas Nat’l Ins. Co. v. De La Cruz" on Justia Law

At issue in this mandamus proceeding was the City of Houston’s equal rights ordinance. Relators - two signers of a referendum petition calling for the repeal of the ordinance - contested the wording of the ballot language. Two days after the City Council adopted the current ballot language, Relators petitioned for emergency and mandamus relief, noting that the deadline for revising the ballot language had not yet passed. The Supreme Court conditionally granted mandamus relief, directing the City Council to word the proposition such that voters will vote directly for or against the ordinance. View "In re Williams" on Justia Law

After the Houston City Council adopted an equal rights ordinance, Relators - residents of the City of Houston - organized a petition drive calling for the City Council to repeal the ordinance or put it to popular vote. The City Secretary certified the petition’s sufficiency, but the City Council denied it, claiming that the petition was invalid because it lacked the required number of valid signatures. Relators sought mandamus relief. The Supreme Court conditionally granted mandamus relief, holding (1) Relators did not have an adequate remedy by way of appeal for lack of sufficient time for the appeal to be finally resolved; and (2) the City Council did not perform its ministerial duty to immediately reconsider the ordinance after the City Secretary certified the petition’s sufficiency and, if it did not repeal it, to put it on the November 2015 ballot. View "In re Jared Woodfill" on Justia Law

Respondent sued Petitioners and attempted to serve Petitioners by using Petitioners’ registered address on file with the Secretary of State’s office. Petitioners, however, had moved several years earlier and had failed to provide an updated registered address to the Secretary of State. Petitioners did not answer the lawsuit, and Respondent obtained a default judgment. Pursuant to Tex. R. Civ. P. 239a, Respondent certified Petitioners’ outdated address as their last known mailing address, even though there was some evidence Respondent had actual notice of Petitioners’ current address. Petitioners failed to receive notice of the default judgment. Petitioners filed a petition for an equitable bill of review, asserting that Respondent had not properly served them with process and not had properly certified their last known mailing address for notice of the default judgment. The trial court granted Respondent’s motion for summary judgment. The court of appeals affirmed. The Supreme Court reversed, holding that because Petitioners presented some evidence that their failure to receive notice of the default judgment resulted solely from Respondent’s failure to properly certify Petitioners’ last known mailing address, and not from any negligence or fault on Petitioners’ part, Petitioners raised a genuine issue of material fact in their bill-of-review claim. View "Kay Venture, Ltd. v. Cremona Bistro Corp." on Justia Law

This case involved a boundary dispute between the City of Ingleside and the City of Corpus Christi over the scope of an ordinance establishing the adjacent bay waters’ “shoreline” as the common border. Each city claimed that several piers, bulkheads, wharves, and artificial structures affixed to Ingleside’s shore and projecting into bay waters fell within its jurisdictional boundaries. Ingleside sued Corpus Christi seeking a declaration that the structures were functionally part of the land and therefore were within the jurisdiction of the land side of the shoreline. The court of appeals concluded that the trial court lacked jurisdiction to establish the boundary between the two cities because the issue was a purely political question not subject to judicial review. The Supreme Court reversed, holding that whether natural and artificial conditions are protrusions of the “shoreline” is a justiciable issue materially distinct from a legislative determination about where to establish a municipal boundary line, and therefore, Ingelside’s declaration did not require the court to address a political question beyond the Court’s competence or authority. Remanded. View "City of Ingleside v. City of Corpus Christi" on Justia Law