The case is a petition for writ of mandamus before the Supreme Court of Texas in In re Demaree Reed, involving questions about the primary-jurisdiction doctrine in a dispute that may implicate agency authority over a FELA matter. The concurring opinion agrees with the Court's resolution but does not decide the underlying dispute, instead focusing on the doctrine's development. It traces the doctrine to its federal origins in cases like Texas & Pacific Railway Co. v. Abilene Cotton Oil Co., where it required courts to defer to agencies like the ICC on issues within their exclusive jurisdiction to promote uniformity and avoid branch friction. The concurrence argues that the doctrine's expansion beyond its original narrow scope may now hinder judicial functions and proposes considering a return to its initial formulation or alternatives such as amicus briefs in future cases.
The case concerned whether qui tam claims under the Texas Health Care Program Fraud Prevention Act survive the death of the relator. The Supreme Court of Texas held that the claims do survive the relator's death. The core reasoning was that the claims belong to the State, which is the party allegedly injured and remains in existence. Concurring justices agreed with this holding on the narrow question presented but noted that other issues, such as standing and separation of powers under the Act, were not raised and may require future resolution.
This case concerns whether sovereign immunity bars JRJ Pusok Holdings, LLC from bringing a repurchase claim against the State of Texas under Chapter 21 of the Texas Property Code following an eminent-domain action. The Supreme Court of Texas held that sovereign immunity does not prevent such suits. The core reasoning is that by locating the statutory repurchase right within the comprehensive eminent-domain provisions of Chapter 21—where sovereign immunity is already understood not to apply—the legislature effected a clear and unambiguous waiver of immunity. Justice Young concurred, agreeing with the result but arguing that the analysis should rest solely on the statute’s text and placement rather than additional factors from prior precedent.
This case involved the Texas Department of Family and Protective Services seeking termination of both parents' rights to their three children, based on the father's history of self-harm, threats of violence, and physical aggression toward the mother in the children's presence, along with the mother's alleged failure to protect them. A jury found grounds for termination as to both parents, the trial court entered judgment accordingly, and the court of appeals affirmed. The Texas Supreme Court affirmed termination of the father's rights, concluding that legally sufficient evidence supported findings that he endangered the children and that termination was in their best interest. The Court reversed as to the mother, holding that the government failed to meet the clear-and-convincing-evidence standard to show termination of her rights was in the children's best interest, given the strong presumption against termination and the statutory preference for family rehabilitation over severance of parental bonds. The Court rendered judgment in the mother's favor while noting she would become the children's sole legal parent.
This case involved a proceeding by the Texas Department of Family and Protective Services to terminate a mother's parental rights to her two children. The Supreme Court of Texas held that neither the trial court nor the court of appeals had subject-matter jurisdiction to decide the case on the merits. Under Texas Family Code § 263.401(a), the trial court's jurisdiction automatically terminated on the one-year anniversary of the temporary conservatorship order because no trial on the merits had begun and no valid extension had been granted beforehand. The court reasoned that an attempted oral extension at a pretrial hearing was ineffective, particularly given the absence of a proper court reporter and the lack of any written order before the deadline, making dismissal mandatory by operation of law without judicial action.
The case involved a dispute between MV Transportation, Inc. and GDS Transport, LLC arising from a subcontract for providing vehicles and drivers for paratransit and microtransit services under a master agreement with the Dallas Area Rapid Transit Authority (DART). GDS sued MV Transportation for fraud, among other claims, but the trial court dismissed the fraud claim under Texas Rule of Civil Procedure 91a. The Supreme Court of Texas held that the dismissal was proper because the allegations in the petition established that MV Transportation was exercising DART's functions pursuant to the contract, making it liable for damages only to the extent DART would be, and DART could not be held liable for fraud under Tex. Transp. Code § 452.056(d). The court reversed the court of appeals' decision that had reinstated the fraud claim and remanded the remaining case to the trial court. The core reasoning was that the live pleading confirmed MV Transportation's contractual authority to manage DART's operations, triggering the statutory limitation on liability.
The case concerns a challenge by multiple individuals and one school district against South Texas Independent School District, focusing on whether the plaintiffs met the requirements to bring suit. The Texas Supreme Court held that the plaintiffs satisfied traditional standing rules and that the case should proceed to adjudication on the merits. The core reasoning is that standing exists when a plaintiff shows a direct, individualized injury traceable to the defendant's conduct and redressable by the requested relief; extraneous factors such as potential governmental inconvenience or generalized policy objections have no place in the standing analysis. The concurrence further explains that references to "taxpayer standing" are often imprecise labels for claims that already meet ordinary constitutional standing criteria, particularly when plaintiffs allege unlawful collection or expenditure of tax funds affecting them personally.
The case concerned whether the commissioner of the Texas Department of State Health Services has authority to classify manufactured delta-8 THC products as controlled substances under the Texas Controlled Substances Act following the 2019 Texas Farm Bill's exclusion of hemp and its THC from that Act. Businesses selling such products sued for a temporary injunction, arguing that the commissioner's actions were ultra vires because the legislature had legalized those products. The trial court and court of appeals granted relief, but the Texas Supreme Court reversed, holding that sovereign immunity barred the claims and that the Act's text, structure, and history preserved the commissioner's discretion to schedule the substances. The Court further noted that any change to legalize potent manufactured THC would require clear legislative action rather than judicial intervention. It affirmed the lower court's standing ruling but rendered judgment reversing the injunction.
This case involves a dispute between Spectrum Gulf Coast, a telecommunications provider, and the City of San Antonio's public utility CPS Energy over pole-attachment fees for equipment on utility poles. Spectrum alleged that CPS violated the Public Utility Regulatory Act (PURA) by charging discriminatory rates, breaching their 1984 contract which required compliance with all applicable laws. The Texas Supreme Court held that the contract's language, obligating parties to observe and comply with all laws affecting their rights at all times and making the agreement subject to such laws, incorporates statutory requirements like PURA's anti-discrimination provisions into the enforceable contract terms. Therefore, the court reversed the court of appeals' contrary decision and remanded the case to the trial court for further proceedings on Spectrum's breach-of-contract claims.
This case concerned the interpretation of a 1951 royalty deed conveying mineral interests in Texas land, specifically whether the language "1/128 (1/16 of the usual 1/8 royalty)" granted a fixed 1/128 royalty or a floating 1/16 royalty. The Texas Supreme Court decided that the deed conveyed a fixed 1/128 interest, reversing the court of appeals and reinstating the trial court's summary judgment. The court reasoned that the deed's plain language rebutted the presumption from Van Dyke v. Navigator Group that double fractions refer to the entire interest, as the parties used 1/8 for its numerical value. Although the presumed-grant doctrine was discussed due to decades of consistent practice, the textual interpretation alone supported the fixed interest.
The case concerned whether S&B Engineers and its insurer Zurich could enforce contractual indemnification provisions against subcontractor Scallon Controls to recover amounts paid in a settlement with workers injured in a 2015 refinery accident allegedly caused by Scallon's faulty fire-suppression system. After the workers settled their tort claims against S&B and Sunoco, Scallon obtained summary judgment on the ground that the voluntary settlement extinguished any indemnity rights, relying on 1987 precedents addressing contribution and indemnity. The Texas Supreme Court reversed, holding that those precedents do not preclude enforcement of a freely negotiated contractual proportional-indemnification clause that disclaims coverage for the indemnitee's own negligence and satisfies the express-negligence doctrine; the Court further held that Zurich's subrogation claim was timely because the limitations period began when liability became fixed by the settlement. The case was remanded for proceedings to determine whether the settlement amount was reasonable and the extent of any fault attributable to Scallon.
The case concerned a trial court's termination of a mother's parental rights to her child despite statements by the Texas Department of Family and Protective Services' designated representative at trial that the department sought only to restrict those rights and appoint the father as sole managing conservator. The department did not repudiate or correct those statements during the proceedings. The Supreme Court of Texas reversed the termination judgment, holding that in parental-termination cases a court may not terminate rights when faced with an unequivocal and unrepudiated statement by the department's representative withdrawing termination as requested relief. The court reasoned that the department had multiple opportunities to clarify its position but failed to do so, effectively abandoning its termination claim as to the mother.
The case arose from a trucking accident that caused deaths and injuries, leading to tort claims against the driver and derivative negligence claims such as negligent entrustment, hiring, and supervision against the employer Werner Enterprises. The Supreme Court of Texas held that tort liability may not be imposed as a matter of law. Because this antecedent question was resolved in favor of the defendants, the Court did not reach the admission rule, which provides that an employer's admission of vicarious liability for an employee's negligence renders separate derivative claims against the employer unnecessary and improper. As a result, the court of appeals' prior discussion of the admission rule, including any potential gross-negligence exception, is no longer precedent, and lower courts may address the issue in the ordinary course.
The case concerned Southern Methodist University’s 2019 attempt to amend its articles of incorporation to remove all references to and authority of the South Central Jurisdictional Conference of the United Methodist Church, despite the articles expressly requiring the Conference’s approval for any changes. The Supreme Court of Texas held that the Conference could bring suit under § 22.207 of the Texas Business Organizations Code for a declaratory judgment on whether the amendments were valid and, if not, to restore the Conference’s rights. The core reasoning was that the statute specifically preserves religious organizations’ authority to control affiliated nonprofit corporations and authorizes them to seek judicial enforcement of that control, overriding more general statutory limits on such actions.
The case concerned whether Texas district courts may issue writs of mandamus to compel the Attorney General and Governor to comply with requests under the Public Information Act. The Supreme Court of Texas held that the legislature has not authorized district courts to enforce the Act through mandamus against constitutional executive officers. The core reasoning rests on the statutory text of the Public Information Act, which does not vest such authority in district courts, consistent with prior precedent in A & T Consultants, Inc. v. Sharp. The Court therefore resolved the dispute on statutory grounds without reaching separate constitutional questions about mandamus jurisdiction over the governor.
This case involved Texas residents suing an Austrian aircraft engine manufacturer, BRP-Rotax, for strict liability, negligence, and gross negligence after an engine failure caused a plane crash in Texas that injured one plaintiff. The sole issue was whether Texas courts could exercise specific personal jurisdiction over Rotax under the stream-of-commerce-plus test. The Texas Supreme Court held that they could not, reversing the lower courts and dismissing the claims against Rotax. The Court reasoned that the record showed no purposeful availment by Rotax of the Texas market, as the company manufactured engines only in Austria, sold them exclusively to foreign distributors with no direct ties to Texas, and did not target or control distribution to Texas; any connection resulted from the independent actions of third parties.
The case concerns the Texas Attorney General's efforts to investigate Annunciation House, an El Paso nonprofit that provides shelter to immigrants, by demanding its records to determine whether it has unlawfully harbored illegal aliens, and to pursue a quo warranto action that could revoke the organization's charter. The trial court ruled that certain statutes authorizing the records request were unconstitutional, granted injunctions blocking the Attorney General's actions, and denied leave to file the quo warranto proceeding. The Supreme Court of Texas reversed those holdings, concluding that the Attorney General possesses constitutional authority to initiate the quo warranto action and that the trial court's constitutional rulings and related injunctions were premature. The Court emphasized that the merits of the underlying allegations, including any religious liberty defenses, should be addressed through normal litigation processes on remand rather than resolved at this early stage.
The case involved a challenge by detained immigrant mothers and advocacy groups to a Texas DFPS rule authorizing state licenses for two facilities used by the federal government to detain mothers and children after illegal entry into the U.S. The court of appeals found the claims moot after the plaintiffs were released but applied a 'public-interest exception' to reach the merits and invalidate the rule under the Administrative Procedure Act. The Texas Supreme Court held that Texas courts lack constitutional authority to decide moot cases, as this would constitute prohibited advisory opinions under the judicial power provision of the Texas Constitution. The court reasoned that recognized mootness exceptions preserve live controversies rather than creating true exceptions to justiciability requirements. It reversed the jurisdictional holding, vacated the merits rulings, and dismissed the case for lack of subject-matter jurisdiction.
The case involved Noel Powell suing the City of Austin for injuries sustained when a police officer's vehicle collided with his minivan during a high-speed chase of a suspect who had fled after gunshots were reported. The Texas Supreme Court held that the City's governmental immunity was not waived under the Tort Claims Act's emergency exception because the officer was responding to an emergency situation, complied with applicable laws, and did not act with reckless disregard. The court reasoned that the evidence did not raise a fact issue regarding recklessness, reversing the court of appeals and dismissing the case for lack of jurisdiction.
This case concerns an employment discrimination claim brought by Loretta K. Flores against Texas Tech University Health Sciences Center-El Paso under Texas Labor Code Chapter 21, alleging an unlawful hiring decision for a chief of staff position based on a protected characteristic. The Texas Supreme Court ruled in favor of the university, holding that the claim lacked merit and affirming dismissal under existing precedents. The core reasoning applied the McDonnell Douglas burden-shifting framework, borrowed from federal Title VII law, to evaluate whether the plaintiff had produced sufficient evidence of discrimination at each stage, ultimately concluding that the university's decision was legitimate and nondiscriminatory. The concurrence agrees with this outcome but notes that the framework was adopted with minimal analysis tying it to the statute's general purpose of aligning with federal policy.