Justia Texas Supreme Court Opinion Summaries

Petitioner owned and operated a charter bus that collided with a car driven by Respondent. Respondent filed this negligence action against Petitioner seeking damages for the injuries he sustained in the collision. Before trial, Respondent filed a motion for spoliation of evidence requesting that Petitioner be sanctioned because it destroyed a video recording of the accident. The trial court orally ruled that Petitioner had negligently spoliated evidence and ordered the inclusion of a spoliation instruction in the jury charge. The jury found in Respondent’s favor. Petitioner appealed, arguing that the trial court erred in submitting the spoliation instruction. The court of appeals affirmed, concluding that Petitioner waived any complaint it had about the instruction. The Supreme Court reversed, holding (1) Petitioner preserved error by responding to the pretrial motion for sanctions, even while failing to formally object to the instruction’s inclusion in the jury charge until after it was read to the jury; and (2) the trial court committed reversible error by submitting the instruction. Remanded for a new trial. View "Wackenhut Corp. v. Gutierrez" on Justia Law

In this case, the Supreme Court overruled its long-standing rule prohibiting self belt evidence in car accident cases. This ruling was the result of the Legislature’s overhaul of Texas’s system for apportioning fault in negligence cases and the change in law requiring seat belt use. The trial court in the instant case relied on the Court’s precedent in prohibiting seat belt evidence. The court of appeals affirmed the trial court’s judgment solely on the ground that seat belt evidence was properly excluded. The Supreme Court reversed, holding that relevant evidence of use or nonuse of seat belts is admissible for the purpose of apportioning responsibility in civil lawsuits, provided that the plaintiff’s conduct caused or was a cause of his damages. Remanded. View "Nabors Well Servs., Ltd. v. Romero" on Justia Law

A judgment creditor attempted to collect from a partnership after receiving a judgment against the partnership. The partnership proved to be undercapitalized, and its assets could not satisfy the judgment debt. The judgment creditor brought this action seeking a judgment against the individual partners. The trial court granted the partners’ motion for summary judgment. The court of appeals affirmed, concluding that limitations precluded pursuit of the partners’ assets because the limitations period began when the underlying cause of action accrued, and that period had passed. The court of appeals affirmed. The Supreme Court reversed, holding (1) the limitations period against a partner generally does not commence until after final judgment against the partnership is entered; and (2) because this action was brought within that period, limitations did not bar this suit against the partners. View "Am. Star Energy & Minerals Corp. v. Stowers" on Justia Law

Southwestern Bell Telephone, LP, doing business as AT&T Texas, was a public utility company with facilities attached to a city bridge designated for destruction. AT&T sued the City of Houston and the Harris County Commissioners seeking an injunction preventing the removal of its facilities from the bridge and a declaratory judgment that Tex. Water Code Ann. 49.223 required the Harris County Flood Control District to bear any relocation costs. The trial court granted summary judgment to the City and the Commissioners’ pleas to the jurisdiction. The court of appeals affirmed, concluding that the relocation costs sought by AT&T were not clearly within the statute’s purview. The Supreme Court reversed, holding that AT&T was entitled to declaratory relief that payment of its relocation expenses by the District was required by section 49.223. View "Southwestern Bell Telephone, LP v. Emmett" on Justia Law

Invoking the Texas Public Information Act (PIA), Randall Kallinen requested information from the City of Houston regarding a study of traffic light cameras the City had commissioned. The City withheld some documents and asked the Attorney General for an opinion as to whether the PIA excepted the withheld information from disclosure. Before the Attorney General ruled, Kallinen sued for a writ of mandamus to compel the City to disclose the withheld information. The City filed a plea to the jurisdiction, arguing that the court lacked jurisdiction over the suit until the Attorney General ruled. The district court overruled the plea, ordered disclosure of the withheld documents, and awarded Kallinen attorney fees. The court of appeals reversed, holding that a trial court lacked subject matter jurisdiction over this suit until the Attorney General ruled. The Supreme Court reversed, holding that the court of appeals erred in dismissing Kallinen’s suit for want of jurisdiction, as a requestor of information is not required to defer a suit for mandamus while awaiting the Attorney General’s decision. View "Kallinen v. City of Houston" on Justia Law

A property developer filed suit against several defendants involved in a construction project asserting claims for negligence and breach of contract. Defendants filed motions to compel arbitration, which the trial court denied. The court of appeals affirmed. The Supreme Court held that the developer must arbitrate its claims against the general contractor but not its claims against the other defendants, as (1) the developer agreed to arbitrate its claims against the general contractor, and the general contractor did not waive its right to demand arbitration; (2) the developer’s argument that a contractual deadline barred the general contractor’s demand for arbitration was itself a claim that must be arbitrated; (3) the developer did not agree in the general contract to arbitrate its claims against the other defendants; (4) the developer was not equitably estopped from denying its assent to its purported agreement that the other defendants could enforce the general contract’s arbitration provisions; and (5) the subcontracts did not require the parties to arbitrate these claims. View "G.T. Leach Builders, LLC v. Sapphire V.P., L.P." on Justia Law

Donald and Crystal Peel were traveling in their van when they were struck by a truck driven by Michael Conner and owned by Conner's employer. In 2004, the Peels sued Conner and his employer (collectively, Conner). Conner timely answered and requested discovery. The Peels did not respond. In 2013, when the Peels had done nothing to pursue their claims, Conner moved to dismiss for want of prosecution. The trial court refused to dismiss and directed the Peels to respond to Conner’s requests for discovery served more than eight years earlier. Conner filed a petition for mandamus directing the trial court to dismiss the case. The court of appeals denied relief. Conner subsequently petitioned the Supreme Court. The Supreme Court conditionally granted the petition for writ of mandamus and directed the trial court to vacate its order denying Conner’s motion to dismiss and directed the court to dismiss this suit for want of prosecution. View "In re Conner" on Justia Law

Elisa Zapata died while under the care of the Fredericksburg Care Company, LP, a nursing home. Zapata’s death and survival beneficiaries sued Fredericksburg, alleging negligent care and wrongful death. Fredericksburg filed a motion to compel arbitration based on an arbitration clause contained in an agreement that Zapata signed prior to her admission in the nursing home. The trial court denied the motion to compel arbitration, concluding (1) the pre-admission agreement’s arbitration clause did not comply with Tex. Civ. Prac. & Rem. Code Ann. 74.451 and was therefore invalid; and (2) the McCarran-Ferguson Act (MFA) applied in this case, thus triggering the exemption under which the Federal Arbitration Act (FAA) would not preempt the state statute. The court of appeals affirmed. The Supreme Court reversed, holding that the MFA does not exempt section 74.451 from preemption by the FAA, and the trial court should have granted Fredericksburg’s motion to compel arbitration. View "Fredericksburg Care Co., LP v. Perez" on Justia Law

Petitioners and Respondents were adjacent landowners who disputed ownership of a tract of land in a heavily wooded area. Respondents asserted record title to the tract. Petitioners asserted adverse possession. Respondents filed a suit to quiet title and a declaratory judgment action. The trial court granted summary judgment for Petitioners, concluding that Respondents did not have record title. The court of appeals reversed, concluding that Respondents had record title to the tract, and remanded to the trial court to consider Petitioners’ adverse possession claim. The Supreme Court reversed the judgment of the court of appeals and affirmed that of the trial court, holding that Respondents did not have record title to the tract. View "Stribling v. Millican DPC Partners, LP" on Justia Law

At issue in this oil and gas dispute was the validity of a mineral lease on nearly two thousand acres of land in north Texas. The non-participating royalty interest holder (non-executive) claimed the executive-right holder (executive) procured the mineral lease in breach of a duty of good faith owed to her. The non-executive further alleged that the lessee acted in concert with the executive in facilitating the breach of duty and that the executive’s ill-gotten gains were fraudulently transferred to third parties. The trial court granted a take-nothing summary judgment on all claims. The court of appeals reversed, concluding that issues of material fact existed that precluded summary judgment. The Supreme Court affirmed in part and reversed in part, holding (1) fact questions precluded summary judgment as to the non-executive’s breach-of-duty claim against the executive; but (2) summary judgment was proper as to the claims against the remaining defendants. View "KCM Financial LLC v. Bradshaw" on Justia Law