Justia Texas Supreme Court Opinion Summaries

The Texas Student Housing Authority (TSHA) had title to the Cambridge at College Station, a student-residential facility near two college campuses. In the summers of 2005 to 2008, TSHA provided lodging at the Cambridge to non-college students attending university-sponsored instructional programs. The Brazos County Appraisal District (BCAD) voided TSHA’s property-tax-exempt status for the years 2005 to 2008 and assessed millions of dollars of back taxes. The trial court affirmed, concluding that TSHA forfeited the exemption once the Cambridge hosted people who were not students, faculty or staff members of an institution of higher learning. The court of appeals affirmed. The Supreme Court reversed, holding that TSHA did not forfeit its exemption under Tex. Educ. Code Ann. 53.46 by housing summer program participants at the Cambridge because the statute imposes no conditions but rather declares the property-tax exemption in absolute terms. View "Tex. Student Housing Auth. v. Brazos County Appraisal Dist." on Justia Law

The State condemned two adjacent parcels of property that the owners had leased to Clear Channel Outdoor Inc. for outdoor advertising. Clear Channel had built a billboard on each parcel. The State maintained that its condemnation of the realty did not include the billboards themselves because they were removable property for which no compensation was due. Consistent with the State’s position, the special commissioners’ awards included no compensation for the billboard structures. The landowners and Clear Channel objected to the awards. In addition, Clear Channel counterclaimed for inverse condemnation of the sign structures. After a jury trial, the trial court awarded Clear Channel $268,235.27 for the billboards less credits for the amounts already received from the commissioners’ award, concluding that a billboard may be a fixture to be valued with the land. The court of appeals affirmed. The Supreme Court reversed, holding (1) Clear Channel’s billboard structures were fixtures and should have been valued as part of the land; and (2) while Clear Channel was due compensation for the sign structures, it was not entitled to value the structures based on the income from its advertising operations, and evidence of that income was inadmissible. Remanded. View "State v. Clear Channel Outdoor, Inc." on Justia Law

Two nonresident minors filed suit against Bridgestone Americas Tire Operations, LLC, the manufacturer of an allegedly defective tire that failed, causing a rollover that killed the children’s parents. The minors sued by a next friend - their uncle - who was a Texas resident. The residents resided in Mexico with their grandparents, who became the children’s legal guardians. Bridgestone filed a motion to dismiss for forum non conveniens, asserting that the case belonged in Mexico, not Texas. The trial court denied the motion. Bridgestone petitioned for writ of mandamus in the court of appeals. The court denied relief, concluding that because the next-friend was a Texas resident the case may not be dismissed on forum-non-conveniens grounds. Bridgestone subsequently sought mandamus relief in the Supreme Court. The Supreme Court conditionally granted Bridgestone’s petition for writ of mandamus and ordered the trial court to dismiss the action, holding (1) Texas law allows minors to sue by next friend when they have a legal guardian who is not authorized to sue in Texas in that capacity; (2) a next friend is not a plaintiff for purposes of the forum-non-conveniens statute’s Texas-resident exception; and (3) therefore, this case must be dismissed as a matter of law. View "In re Bridgestone Americas Tire Operations, LLC" on Justia Law

This dispute arose from the 2010 explosion and sinking of the Deepwater Horizon oil-drilling rig, which killed eleven people and resulted in extensive subsurface discharge of oil into the Gulf of Mexico for nearly three months. The issue in this case concerned the extent of insurance coverage afforded to the oil-field developer, BP, as an additional insured under primary- and excess-insurance policies procured by Deepwater’s owner, Transocean. The U.S. Court of Appeals for the Fifth Circuit certified to the Supreme Court two questions regarding the interplay between the insurance policies and provisions in a drilling contract giving rise to Transocean’s obligation to name BP as an additional insured. The Court held (1) BP is not entitled to coverage under the Transocean insurance policies for damages arising from the subsurface pollution because BP, not Transocean, assumed liability for such claims; and (2) based on the Court’s analysis of the first issue, it did not reach the second question. View "In re Deepwater Horizon" on Justia Law

A landowner sued its neighbor, the operator of an adjacent wastewater disposal facility, alleging that wastewater had migrated into the deep subsurface of its land, possibility contaminating the groundwater beneath it. The jury returned a verdict in favor of the wastewater disposal facility. After a series of appeals, the court of appeals reversed the jury’s verdict. The Supreme Court reversed the judgment of the court of appeals and reinstated the trial court’s judgment that the wastewater disposal facility take nothing, holding (1) the jury instruction properly included lack of consent as an element of a trespass cause of action that a plaintiff must prove; (2) the trial court properly denied the landowner’s motion for directed verdict on the issue of consent; and (3) there is no need to address the remaining question of whether deep subsurface wastewater migration is actionable as a common law trespass in Texas. View "Envtl. Processing Sys., LC v. FPL Farming Ltd." on Justia Law

Respondents obtained a home-equity loan from Wells Fargo Bank. After Respondents stopped making loan payments, Wells Fargo filed an application in the district court for an expedited court order authorizing foreclosure. Respondents filed a separate and original declaratory judgment action that invoked the automatic stay and dismissal provisions of Tex. R. Civ. P. 736.11. Wells Fargo filed an amended answer asserting a counterclaim for declaratory judgment and requesting attorney’s fees pursuant to the Uniform Declaratory Judgments Act. The trial court granted Wells Fargo’s motion for summary judgment and awarded attorney’s fees, concluding that Respondents had defaulted on their home-equity loan. The court of appeals affirmed the trial court’s summary judgment but reversed the attorney’s fee award, concluding that neither party had pleaded a cognizable claim for declaratory relief, and the non-recourse status of the home-equity loan prohibited a personal judgment for attorney’s fees against Respondents. The Supreme Court reversed in part, holding (1) because Respondents failed to preserve any challenge to the characterization of their own claim for declaratory relief, the trial court was authorized to enter a judgment awarding Wells Fargo its attorney’s fees; and (2) neither the parties’ loan agreement nor the Texas Constitution prohibited a personal judgment against Respondents for attorney’s fees. View "Wells Fargo Bank, N.A. v. Murphy" on Justia Law

This case arose from the deadly collision of two eighteen-wheeled commercial trucks. Petitioner filed this third-party claim against Fayette County, alleging that the collision was caused by a County deputy sheriff. Petitioner sought redress pursuant to Tex. Civ. Prac. & Rem. Code 101.021, which provides a waiver of governmental immunity when an injury “arises from the operation or use” of a vehicle by a government employee. The trial court sustained the County’s plea to the jurisdiction, concluding that the county remained immune from suit because the accident did not arise from a government employee’s vehicle use. The Supreme Court reversed, holding that Petitioner alleged an injury arising from a deputy sheriff’s vehicle use for the purpose of section 101.021. View "Ryder Integrated Logistics, Inc. v. Fayette County" on Justia Law

Plaintiff, a mineral owner, sued Defendant alleging breach of contract, failure to pay royalties, and fraud. The claims centered on three oil and gas leases that Plaintiff, the lessor, executed with Defendant, the lessee. Plaintiff prevailed on the majority of his claims in the trial court. As relevant to this appeal, the jury determined that Plaintiff, in the exercise of reasonable diligence, discovered the fraud less than four years before filing suit. The trial court therefore concluded that the claims were not time barred. The court of appeals reversed, concluding that the fraud should have been discovered, as a matter of law, more than four years before Plaintiff filed suit because Plaintiff should have discovered the relevant information in the Texas Railroad Commission’s public records. The Supreme Court reversed, holding that Plaintiff’s reasonable diligence in discovering the underlying fraud was a question of fact for the jury. Remanded. View "Hooks v. Samson Lone Star, Ltd. P’ship" on Justia Law

The Office of the Attorney General filed an action against Cornelius Jackson seeking to establish his paternity and to compel him to pay child support. The associate judge issued a temporary order establishing the parent-child relationship and ordering Jackson to pay child support. Additionally, the associate judge denied OAG’s request to prevent disclosure of certain of Jackson’s and the child’s personal information and, finding that no basis existed to show a history of family violence, ordered OAG to remove the family violence indicator from Jackson’s file and OAG’s system. The trial court affirmed and adopted the associate judge’s temporary order. OAG sought mandamus relief. The Supreme Court conditionally granted the writ of mandamus and directed the trial court to vacate its order, holding that the trial court lacked authority to order OAG to remove the indicator from its files. View "In re Office of the Attorney Gen. of Tex." on Justia Law

Farm Bureau County Mutual Insurance Company filed this declaratory judgment action against Cristil Rogers, Farm Bureau’s insured, seeking a declaration that it had no duty to defend or indemnify Rogers in an underlying tort action and requesting court costs and attorney fees. Rogers answered and prayed for recovery of her court costs and attorney fees. The trial court denied Farm Bureau’s motion for summary judgment, concluding that Farm Bureau had a duty to defend Rogers in the tort action. The order did not expressly address the parties’ claims for attorney’s fees. The court of appeals dismissed Farm Bureau’s appeal for lack of jurisdiction, concluding that the order denying Farm Bureau’s motion for summary judgment was not final and appealable because Rogers did not file a cross-motion for summary judgment. The Supreme Court affirmed, holding (1) the fact that Rogers did not file a cross-motion for summary judgment did not preclude the trial court from entering a final judgment; but (2) in the absence of the trial court’s intent with respect to the parties’ claims for attorney’s fees, the order at issue did not dispose of all parties and claims. View "Farm Bureau County Mut. Ins. Co. v. Rogers" on Justia Law