Justia Texas Supreme Court Opinion Summaries

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

Petitioners, former employees of the City of Houston, filed suit against the Houston Municipal Employees Pension System (HMEPS) board members, asserting that the board members violated HMEPS’s enabling statute by requiring Petitioners’ continued participation in the City’s defined-benefit pension plan. The trial court found jurisdiction to be lacking, and the court of appeals affirmed. As provided by statute, the pension board has exclusive authority to interpret and supplement omissions in the statute and to determine all questions of law and fact pertaining to eligibility for membership, services and benefits. The board’s actions with respect to these matters are final and binding and therefore not amenable to judicial review. To defeat this jurisdictional bar, Petitioners asserted that subject-matter jurisdiction exists when the pension board fundamentally alters the terms of the statute without the City’s consent. The Supreme Court affirmed, holding that the trial court lacked subject-matter jurisdiction over the claims because (1) the pension board acted within the scope of its authority in construing the term “employee”; and (2) Petitioners failed to assert viable constitutional claims. View "Klumb v. Houston Municipal Employees Pension Sys." on Justia Law

Respondent borrowed money from Bank pursuant to a construction loan agreement and promissory note. Defendant secured his obligations by executing a deed of trust on property. After Respondent defaulted on the note, Bank foreclosed its contractual deed of trust lien on the property. Bank purchased the property for less than the secured debt. Respondent sued Bank, arguing that Tex. Prop. Code Ann. 51.003 required Bank to offset the property’s fair market value on the date of foreclosure against any judgment in favor of Bank. Bank counterclaimed for damages and attorney’s fees. The trial court rendered judgment for Bank, concluding that section 51.003 did not apply. The court of appeals reversed, determining (1) Respondent’s deficiency must be calculated pursuant to section 51.003, and the term “fair market value” as used in the statute is the historical willing-seller/willing-buyer definition of fair market value; and (2) a factual question existed requiring further proceedings. The Supreme Court reversed, holding (1) section 51.003 applies to this case, but the term “fair market value” in that section does not equate precisely to the historical definition; and (2) the trial court did not err in its finding as to the section 51.003 fair market value of the property on the date of the foreclosure sale. View "PlainsCapital Bank v. Martin" on Justia Law

Gordon Westergren was involved in a lawsuit regarding the purchase of highly desired property. The lawsuit went to mediation, which resulted in National Property Holdings, L.P. (NPH) agreeing to purchase the property. Separately, in exchange for Western’s agreement to settle the lawsuit, Russell Plank, the consultant for NPH, orally promised Westergren that he would receive $1 million plus an interest in the profits from NPH’s future sale of the property. Westergren subsequently signed a release stating that he agreed to relinquish all interest in the property and all claims against NPH and other listed parties in exchange for a total payment of $500,000. Westergren then filed suit, alleging, inter alia, breach of the oral contract and fraud. Defendants asserted that Westergren had released all claims by signing the release and that the oral contract was unenforceable. The jury found in Westergren’s favor on all claims, concluding that Plank fraudulently induced Westergren to sign the release. The Supreme Court held (1) Westergren’s fraudulent inducement failed as a matter of law because he had a reasonable opportunity to read the release before he signed it and elected not to do so; and (2) the oral side agreement did not satisfy the statute of frauds. View "Nat’l Prop. Holdings, L.P. v. Westergren" on Justia Law

Petitioner was court-martialed for sexual abuse and assault and imprisoned for eighteen years. Approximately two decades after the conviction, Petitioner applied to the Texas Department of Licensing and Regulation for a tow truck operator’s license. The Department denied Petitioner’s application based on his conviction. Petitioner contested the denial. An administrative law judge (ALJ) from the State Office of Administrative Hearings recommended that the Department issue a license. The Department, however, revised the ALJ’s findings of fact and conclusions of law to reject Petitioner’s application. The trial court reversed the Department’s decision, concluding that the Department’s alterations of the findings and conclusions were unlawful. The court of appeals reversed, ruling that the Department’s modifications were improper because the ALJ misinterpreted a provision of the Texas Occupations Code concerning licensing restrictions where an applicant has previously been convicted of a crime. The Supreme Court reversed, holding that the Department’s revisions of the findings of fact and conclusions of law constituted error because the revisions were unsupported by the plain language of the statute. View "Thompson v. Tex. Dep’t of Licensing & Reg." on Justia Law

After the State Board for Educator Certification revoked the teaching certificate of a schoolteacher, the schoolteacher sued to overturn the revocation. The trial court concluded that the Board’s decision was not supported by substantial evidence and was arbitrary and capricious. The court issued a permanent injunction prohibiting the Board from revoking the schoolteacher’s revocation and refused to allow the Board to supersede the judgment pending appeal. The State sought mandamus relief challenging the trial court’s denial of supersedeas. The court of appeals denied mandamus relief and abated the merits of the Board’s appeal pending the Supreme Court resolution of a narrow procedural issue. The Supreme Court denied relief, holding that a trial court has discretion to prevent the Board from re-revoking a teacher’s professional license while the Board appeals the court’s rejection of the Board’s initial revocation. View "In re State Bd. for Educator Certification" on Justia Law

After an investigation, the City of Houston declared the Park Memorial condominiums uninhabitable. Because the condominium owners did not apply for an occupancy certificate or make necessary repairs within the requisite period of time, the City ordered all residents to vacate the complex. A group of owners later brought this inverse-condemnation action, alleging that their property was taken when they were forced to vacate. The trial court sustained the City’s plea to the jurisdiction, concluding that the owners had not alleged a taking. The court of appeals reversed. The Supreme Court reversed, holding that the condominium owners’ claim failed because they did not allege a taking. View "City of Houston v. Carlson" on Justia Law

Bill Head, who owns and operates the Silver Spur Truck Stop in Pharr, Texas, hired Petroleum Solutions, Inc. to manufacture and install an underground fuel system. After the discovery that a major diesel-fuel release leak had occurred, Head sued Petroleum Solutions for its resulting damages. Petroleum Solutions filed a third-party petition against Titeflex, Inc., the alleged manufacturer of a component part incorporated into the fuel system, claiming indemnity and contribution. Titeflex filed a counterclaim against Petroleum Solutions for statutory indemnity. The trial court rendered judgment in favor of Head and in favor of Titeflex. The court of appeals affirmed. The Supreme Court (1) reversed as to Head’s claims against Petroleum Solutions, holding that the trial court abused its discretion by charging the jury with a spoliation instruction and striking Petroleum Solutions’ defenses, and the abuse of discretion was harmful; and (2) affirmed as to Titeflex’s indemnity claim, holding that Titeflex was entitled to statutory indemnity from Petroleum Solutions and that any error with respect to the indemnity claim was harmless. View "Petroleum Solutions, Inc. v. Head" on Justia Law

When Richmont Holdings, Inc. bought the assets of Superior Recharge Systems, LLC the parties signed an asset Purchase Agreement that contained an arbitration provision. Superior Discharge’s part-owner, Jon Blake, signed an employment contract to continue as general manager of the business. The contract contained a covenant not to compete but not an arbitration provision. After Blake’s employment was terminated, Superior Recharge and Blake (together, Blake) sued Richmont in Denton County for fraud and breach of contract. Richmont then sued Blake individually in Dallas County to enforce the covenant not to compete. The Dallas County suit was subsequently abated. Nineteen months after being sued, Richmont moved to compel arbitration, asserting that Blake’s claims arose out of the Asset Purchase Agreement. The trial court denied the motion, and the court of appeals affirmed. The Supreme Court reversed. On remand, the court of appeals concluded that Richmont had waived arbitration by substantially invoking the judicial process. The Supreme Court reversed, holding that the circumstances of this case did not approach a substantial invocation of the judicial process. Remanded. View "Richmont Holdings, Inc. v. Superior Recharge Sys., LLC" on Justia Law