This case involved an injured railroad worker who sued his employer under the Federal Employers’ Liability Act (FELA) for negligence, prompting the employer to seek summary judgment on whether it qualified as a “common carrier” under that statute. The trial court referred the common-carrier question to the federal Surface Transportation Board under the primary-jurisdiction doctrine, and the worker sought mandamus relief from that referral order. The Texas Supreme Court held that the trial court abused its discretion because no statute clearly grants the Board authority to decide common-carrier status for purposes of FELA liability. The Court explained that administrative agencies possess only the powers expressly conferred by the legislature and that Texas courts have long resolved such FELA questions themselves. It therefore conditionally granted mandamus relief directing the trial court to vacate the referral.
This case concerned private organizations challenging Texas statutes that authorize temporary closures of Boca Chica Beach for spaceflight safety, arguing the closures violate the public's constitutional right under Article I, Section 33 of the Texas Constitution to unrestricted ingress, egress, and use of state-owned beaches. The Supreme Court of Texas held that the plaintiffs' claims were barred because subsection (d) of the constitutional provision expressly states that it does not create a private right of enforcement, meaning only governmental actors may sue to protect the right. As a result, the private plaintiffs failed to allege a viable claim, governmental immunity was not waived, and the trial court properly dismissed the suit for lack of jurisdiction; the court of appeals' reversal was overturned. The decision rested on the plain text of the amendment, its historical context following the Open Beaches Act, and the principle that courts cannot rewrite constitutional limits on enforcement.
The case involved a disciplinary proceeding against attorney William W. Ruth for allegedly violating Rule 4.02(a), the no-contact rule, by directly serving filings and correspondence on members of the Commission for Lawyer Discipline while he represented himself pro se in an earlier matter. The Supreme Court of Texas held that Rule 4.02(a) does not apply to a lawyer representing only himself. The court's core reasoning was that the rule's prefatory phrase "[i]n representing a client" requires a separate client and therefore excludes self-represented lawyers, leading it to reverse the five-year suspension imposed by the lower courts.
This case involves a challenge to a default judgment entered against respondents Maurice and Ni-Ida Colter in favor of petitioners Huffman Asset Management and Prairie Capital, turning on questions of proper service under Section 5.253 of the Business Organizations Code and related Whitney certificates. The Supreme Court of Texas reversed or declined to uphold the default judgment, consistent with its longstanding practice. The core reasoning is that default judgments are greatly disfavored because they bypass adversarial presentation and adjudication on the merits, requiring strict compliance with statutory and procedural service rules to ensure actual notice whenever reasonably possible. The concurrence catalogs two decades of unanimous or near-unanimous reversals on these grounds, whether based on statutes, rules of procedure, the Craddock test, or due process.
In this case, Emily Lehmberg sued Studio E. Architecture and Interiors, Inc. and others over a home remodel, but failed to file the certificate of merit required by Civil Practice and Remedies Code Section 150.002 with her original petition against the architecture firm, leading to dismissal of those claims without prejudice. The trial court allowed Lehmberg to reassert the claims in an amended petition that included the certificate, and the court of appeals affirmed. The Texas Supreme Court held that when claims against a covered professional are dismissed without prejudice but the underlying lawsuit continues, the plaintiff may reassert them with the required certificate in an amended petition in the same suit. The Court reasoned that the statute's text does not prohibit such an amendment, and a without-prejudice dismissal returns the parties to their pre-suit positions as if the claims against that defendant had never been filed.
This case involves a dispute between neighboring property owners where the Kolles alleged that development by the Kuceras, including a dam and berms, caused flooding and damage to their land, leading to claims of nuisance and violations of the Water Code. The jury awarded economic damages of $425,000 and substantial exemplary damages, but the court of appeals reduced the economic damages to $175,000. The Supreme Court of Texas held that the exemplary damages cap under Civil Practice and Remedies Code Section 41.008 applies to each defendant based on their apportioned percentage of responsibility multiplied by the total economic damages awarded jointly to the plaintiffs, resulting in a cap of $200,000 per defendant here. The court reversed the judgment in part regarding the exemplary damages awards and remanded for the trial court to allocate the capped amounts between the plaintiffs and reassess for constitutional excessiveness.
The case concerned three jointly and severally liable construction companies that posted a single $25 million supersedeas bond to stay enforcement of a judgment exceeding $400 million while appealing. The trial court ruled that the statutory cap in Civil Practice and Remedies Code Section 52.006(b)(2) applied separately to each judgment debtor, leaving two of the companies unsecured and subject to immediate execution. The court held that the $25 million limit on the amount of security applies per judgment debtor rather than per bond, based on the statute's text that refers to security posted by a judgment debtor and incorporates the definition of security from Section 52.001. It granted partial relief by requiring the trial court to give the defendants an opportunity to post additional security before allowing enforcement against the unsecured parties.
This case concerned whether individual taxpayers and Lyford Consolidated Independent School District had standing to challenge South Texas Independent School District's collection of an ad valorem tax originally authorized by Willacy County voters in 1974 for a rehabilitation district serving disabled persons. The Texas Supreme Court held that the court of appeals erred in dismissing the taxpayers' claims for lack of standing but correctly dismissed the school district's claims. The Court reasoned that the individual taxpayers demonstrated direct injury from paying the tax, satisfying standing requirements, while the school district's alleged financial hardship was indirect, not traceable to STISD, and not redressable by the requested relief because school funding is controlled by the Legislature. The case was remanded to address other potential jurisdictional barriers to the taxpayers' claims.
The case involved Ron Valk d/b/a Platinum Construction suing Copper Creek Distributors, Inc. and Jose Doniceth Escoffie for theft of services, tortious interference with contract, and unjust enrichment, based on allegations that Platinum employees were diverted to work on Copper Creek projects. The trial court submitted a spoliation instruction to the jury regarding missing emails and accounting records, and after a verdict for Platinum, the court of appeals found the instruction erroneous and harmful, remanding for a new trial without first addressing other appellate issues. The Texas Supreme Court reversed and remanded to the court of appeals, holding that appellate courts must address points that could result in rendition of judgment before considering remand and that the harm analysis was too narrow because it did not evaluate the entire record.
The case involved a wrongful death lawsuit by the family of Pedro Castaneda, who died in a car accident at an intersection under construction on a Texas highway where traffic signals were not yet operational. The defendant contractors, Third Coast Services and SpawGlass, sought protection under Section 97.002 of the Civil Practice and Remedies Code, which limits liability for contractors performing certain highway construction or repair work for the Texas Department of Transportation. The court of appeals had ruled the statute inapplicable because the contractors lacked direct contracts with TxDOT. The Texas Supreme Court held that the statute does not require contractual privity with TxDOT, that the contractors conclusively established they worked for TxDOT on qualifying highway construction, and reversed the lower court's judgment while remanding for determination of the statute's remaining elements.
In Hannah Mehta v. Manish Mehta, the Supreme Court of Texas addressed whether sufficient evidence supported an award of spousal maintenance to the wife in a divorce proceeding under Texas Family Code Chapter 8. The trial court had awarded Hannah Mehta $2,000 per month in spousal maintenance for 36 months, but the court of appeals reversed that portion, finding insufficient evidence that she would lack sufficient property to meet her minimum reasonable needs. The Supreme Court held that the evidence was legally sufficient, including qualitative evidence of the wife's role as primary caregiver to a medically fragile child requiring substantial care, and that child-related expenses must be considered alongside child support when evaluating the spouse's financial needs. Accordingly, the Court reversed the court of appeals in part and reinstated the trial court's spousal maintenance award.
The case involved a breach of a real estate contract in which White Knight Development purchased property from the Simmonses under an agreement that included a buy-back option if subdivision restrictions were extended before 2018. After the restrictions were extended and White Knight exercised the option, the Simmonses refused to repurchase, leading White Knight to sue for breach and seek both specific performance of the buy-back and various monetary damages related to financing and delay costs. The trial court awarded specific performance along with a monetary award labeled as actual and consequential damages, but the court of appeals eliminated the monetary portion. The Texas Supreme Court held that specific performance of a real estate contract generally precludes additional monetary damages, but a narrow equitable exception allows recovery of reasonable, foreseeable expenses directly traceable to the delay in performance and incurred in connection with care and custody of the property. The Court reversed the court of appeals in part and remanded for review of which portions of the monetary award met these criteria.
The case concerned whether a four-year limitations period under Texas Rule of Disciplinary Procedure 17.06(A) applies to reciprocal attorney discipline proceedings, where Texas imposes discipline mirroring sanctions from another jurisdiction. Attorney Nejla Lane self-reported her 2017 suspension by an Illinois federal court and later by the Illinois Supreme Court for sending improper emails to a magistrate judge's chambers during litigation; the Commission for Lawyer Discipline sought reciprocal discipline in Texas in 2023 based on the later report. The Supreme Court of Texas held that Rule 17.06(A) applies to reciprocal cases and bars the proceedings because the operative grievance was received more than four years after the underlying misconduct. The court reasoned that the rule's text, along with the definitions of grievance and professional misconduct, governs these proceedings and that the Commission's contrary interpretation would permit discipline based on stale reports indefinitely.
This case involved a negligence lawsuit filed by Cleveratta and James Waldroup, individually and as next friends of their minor child R.W., against physician Maurice N. Leibman based on statements in letters he wrote while providing medical care to the patient. The Supreme Court of Texas held that the claim was not a health care liability claim under the Texas Medical Liability Act, so the plaintiffs were not required to serve an expert report and the claim could proceed. The majority reasoned that the underlying facts, as pleaded, allowed the claim to be treated independently rather than as an inseparable part of medical services. The dissent argued that precedents require classifying such claims as health care liability claims subject to the Act's expert-report requirement and dismissal with prejudice for noncompliance.
In this medical malpractice case, Jared Bush sued a hospital and its parent company after his wife died from an undiagnosed pulmonary embolism, alleging the hospital failed to implement adequate protocols for evaluating and treating such conditions. The trial court twice found the plaintiff's expert report sufficient under Texas law, but the court of appeals reversed and dismissed the claims against the hospital. The Texas Supreme Court reversed the court of appeals, holding that the trial court did not abuse its discretion because the amended expert report adequately summarized the expert's opinions on the hospital's standard of care, breach, and causation related to its policies and procedures. The court emphasized that at this stage, only the adequacy of the report under Chapter 74 is at issue, not ultimate liability.
The case concerned whether out-of-state clients could use Texas Government Code Section 82.0651 to void contingency-fee contracts with Texas lawyers after alleged barratry solicitations occurred in Louisiana and Arkansas. The trial court granted summary judgment dismissing the statutory claims, the court of appeals reversed in part, and the Texas Supreme Court reversed that portion of the appellate judgment. The Court held that the statute does not apply extraterritorially because its focus—the prohibited solicitation of legal-services contracts—took place entirely outside Texas, invoking the presumption that civil statutes lack extraterritorial effect absent clear legislative intent to the contrary. It therefore rendered judgment that the clients take nothing on the Section 82.0651 claims but allowed their separate breach-of-fiduciary-duty claims to proceed and remanded those for trial.
A Colorado real estate investment trust sued a Texas hedge fund and its employees for damages from an allegedly defamatory article published under a pseudonym as part of a short-selling strategy, after the claims were dismissed in Colorado federal court for lack of personal jurisdiction. The defendants moved in Texas state court to dismiss under the Texas Citizens Participation Act (TCPA) and for summary judgment on collateral estoppel grounds. The trial court granted both motions, but the court of appeals reversed. The Supreme Court of Texas agreed that collateral estoppel did not apply because the Colorado and Texas proceedings did not involve identical issues or parties, but held that the TCPA dismissal order was not void and required merits review. The court therefore affirmed in part, reversed in part, and remanded for further proceedings.
In Pitts v. Rivas, a client sued his accountants and their firm for fraud and breach of fiduciary duty, alleging that an informal fiduciary relationship arose from their close personal friendship and his subjective trust in them, despite the accountants not occupying a legally recognized fiduciary role. The Texas Supreme Court held that the anti-fracturing rule barred the fraud claim and that the breach of fiduciary duty claim failed because no fiduciary duty existed on the undisputed facts. The concurring opinion emphasized that fiduciary duties arise only when a person undertakes a role that Texas law recognizes as fiduciary, such as trustee, guardian, or corporate director, which confers legal authority over another's affairs; subjective feelings of trust in a business or social relationship do not create such duties. It argued against recognizing "informal" fiduciary relationships based on vague personal connections, as this leads to unpredictable outcomes and imposes onerous burdens without clear standards.