Justia Civil Procedure Opinion Summaries

This case involves a dispute over a provision in a collective bargaining agreement between the City of Austin and the Austin Firefighters Association. The provision, known as Article 10, grants 5,600 hours of "Association Business Leave" (ABL) annually for firefighters to conduct union-related activities. The petitioners, including the State of Texas and several individuals, argued that Article 10 violates the "Gift Clauses" of the Texas Constitution, which prohibit governmental entities from making gifts of public resources to private parties. They contended that the ABL provision improperly benefits the union by allowing firefighters to use paid time off for union activities, some of which they alleged were misused for improper purposes.The case was initially dismissed under the Texas Citizens Participation Act (TCPA), with the trial court granting relief to the Association, including the award of fees and sanctions. On appeal, the trial court's findings of fact went unchallenged, and the focus was primarily on whether the agreement itself violated the Gift Clauses.The Supreme Court of Texas held that Article 10 does not violate the Gift Clauses. The court found that the provision is not a gratuitous gift but brings a public benefit, serves a legitimate public purpose, and the government retains control over the funds to ensure that the public purpose is achieved. The court emphasized that the ABL must be used for activities that directly support the mission of the Fire Department or the Association and are consistent with the Association’s purposes. The court also reversed the trial court's order granting the Association's TCPA motion to dismiss and its award of sanctions and fees against the original plaintiffs. View "BORGELT v. AUSTIN FIREFIGHTERS ASSOCIATION, IAFF LOCAL 975" on Justia Law

The case involves Dianne Hensley, a justice of the peace in Texas, who announced that due to her religious beliefs, she would not perform weddings for same-sex couples but would refer them to others who would. The State Commission on Judicial Conduct issued her a public warning for casting doubt on her capacity to act impartially due to the person's sexual orientation, in violation of Canon 4A(1) of the Texas Code of Judicial Conduct. Hensley did not appeal this warning to a Special Court of Review (SCR) but instead sued the Commission and its members and officers for violating the Texas Religious Freedom Restoration Act (TRFRA) and her right to freedom of speech under Article I, Section 8 of the Texas Constitution. The trial court dismissed her claims for lack of jurisdiction, and the court of appeals affirmed.The Supreme Court of Texas held that Hensley's suit was not barred by her decision not to appeal the Commission’s Public Warning or by sovereign immunity. The court affirmed the part of the court of appeals’ judgment dismissing one of Hensley's declaratory requests for lack of jurisdiction, reversed the remainder of the judgment, and remanded to the court of appeals to address the remaining issues on appeal. The court found that the SCR could not have finally decided whether Hensley is entitled to the relief sought in this case or awarded the relief TRFRA provides to successful claimants. View "HENSLEY v. STATE COMMISSION ON JUDICIAL CONDUCT" on Justia Law

The case involves Angela Horton and Kevin Houser, who sued the Kansas City Southern Railway Company (KC Southern) for the wrongful death of their mother. They alleged that KC Southern negligently maintained a railroad crossing by raising the crossing grade over time to form a “humped crossing” and by failing to replace a missing yield sign. The jury found both parties negligently caused the accident and assigned equal responsibility to each. The trial court awarded Horton fifty percent of the damages. The court of appeals reversed the judgment and remanded for a new trial, holding that federal law preempts a negligence claim based on the humped crossing, but supports a finding that the missing yield sign proximately caused the accident.The Supreme Court of Texas affirmed the court of appeals’ judgment, but on different grounds. The court held that federal law does not preempt the humped-crossing claim and that no evidence supports the jury’s finding that the absence of the yield sign proximately caused the accident. The court concluded that only one of the two allegations could support the jury’s negligence finding, and it could not be certain which of the two allegations the jury relied on. Therefore, the court agreed with the court of appeals that the trial court’s use of a broad-form question to submit the negligence claim constituted harmful error and that a new trial is required. However, the court remanded for a new trial on the humped-crossing allegation rather than on the missing-yield-sign allegation. After further review, the court reversed its previous decision and reinstated the trial court’s judgment, concluding that the submission of the broad-form question did not constitute harmful error. View "HORTON v. THE KANSAS CITY SOUTHERN RAILWAY COMPANY" on Justia Law

The case revolves around a tax appraisal dispute involving Texas Disposal Systems Landfill, Inc. (the Landfill) and Travis Central Appraisal District (the District). The Landfill owns 344 acres of land in Travis County, which it operates as a landfill. In 2019, the District appraised the market value of the landfill at $21,714,939. The Landfill protested this amount under the Tax Code provision requiring equal and uniform taxation but did not claim that the District’s appraised value was higher than the market value of the property. The appraisal review board reduced the appraised value of the subject property by nearly ninety percent. The District appealed to the trial court, claiming that the board erred in concluding that the District’s appraised value was not equal and uniform when compared with similarly situated properties. The District also claimed that the board’s appraised value was lower than the subject property’s true market value.The trial court granted the Landfill’s plea to the jurisdiction, arguing that the challenge it made before the appraisal review board was an equal-and-uniform challenge, not one based on market value. Thus, the trial court lacked jurisdiction to consider market value. However, the court of appeals reversed this decision, holding that a trial court’s review of an appraisal review board’s decision is not confined to the grounds the taxpayer asserted before the board.The Supreme Court of Texas affirmed the court of appeals' judgment. The court concluded that the Tax Code limits judicial review to conducting a de novo trial of the taxpayer’s protest. In deciding the taxpayer’s protest in this case, the trial court is to determine the equal and uniform appraised value for the property subject to taxation. This limit, though mandatory, is not jurisdictional. The case was remanded to the trial court for further proceedings. View "TEXAS DISPOSAL SYSTEMS LANDFILL, INC. v. TRAVIS CENTRAL APPRAISAL DISTRICT" on Justia Law

Roel Canales sued Pay and Save, a grocery store, for injuries he sustained after his foot got stuck in a wooden pallet used to display watermelons, causing him to fall and fracture his elbow. Canales had visited the store hundreds of times before and had purchased watermelons without incident. The wooden pallets, which have open sides to facilitate transport by forklifts and pallet jacks, are a common and necessary tool used by grocery stores to transport and display watermelons due to their size, weight, and shape.The trial court awarded Canales over $6 million in damages. The Court of Appeals for the Fourth District of Texas found the evidence legally but not factually sufficient to support the jury's findings regarding premises liability, reversed the decision, and remanded for a new trial. The court also ruled that Canales take nothing on his gross negligence claim.The Supreme Court of Texas disagreed with the Court of Appeals. It held that the evidence was legally insufficient to support both claims because the wooden pallet was not unreasonably dangerous as a matter of law. The court noted that there was no evidence of prior complaints, reports, or injuries from similar pallets, not just at Pay and Save’s 150 stores, but also at other grocery stores. The court also found no evidence of any code, law, or regulation prohibiting or restricting the use of wooden pallets. The court concluded that the wooden pallet was a common condition, a type of hazard that people encounter and avoid every day by exercising common sense, prudence, and caution. The court reversed the Court of Appeals' judgment in part and rendered judgment for Pay and Save. View "Pay and Save, Inc. v. Canales" on Justia Law

The case revolves around a products-liability claim brought by Jennifer Parks, individually and as the guardian of Samuel Gama, against Ford Motor Company. Gama suffered serious injuries when his 2001 Ford Explorer Sport rolled over. Parks alleged that the Explorer's design made it unstable and prone to rollovers, and that the design of its roof and restraint system increased the risk of injury in a crash. Ford moved for summary judgment, arguing that Parks’ suit is foreclosed by the statute of repose in Section 16.012(b) of the Texas Civil Practice and Remedies Code, which requires that a products liability action be brought within 15 years of the sale of a product.The trial court's proceedings were protracted and winding, with the court initially granting Ford’s summary-judgment motion, then vacating that order and granting Parks’ motion for new trial, then denying Ford’s renewed summary-judgment motion, then denying Ford’s motion for reconsideration of that order, before finally granting another summary-judgment motion by Ford. The evidence that Ford sold the Explorer to a dealership more than 15 years before Parks filed suit was overwhelming.On appeal, the Court of Appeals reversed the trial court's decision, holding that Ford did not conclusively establish the 'date of the sale' from which section 16.012(b)’s claimed protection ran. The court reasoned that Ford was required to establish the specific date on which the dealership paid Ford for the Explorer in full and that Ford has not done so.The Supreme Court of Texas reversed the Court of Appeals’ judgment. The court held that the timing of a sale does not turn on the date of payment, and any inconsistency in Ford’s evidence regarding the timing of the dealership’s payment to Ford for the Explorer is immaterial and not a basis for denying or reversing summary judgment. The court concluded that Ford's evidence easily meets the test of proving that the sale must have occurred outside the statutory period, and thus, Ford is entitled to summary judgment. View "FORD MOTOR COMPANY v. PARKS" on Justia Law

The case revolves around J-W Power Company (J-W Power), a company that leases, sells, and services natural gas compressors used in oil and gas operations. The company maintains these compressors in many counties across Texas and often leases them to customers in neighboring counties. The case specifically involves the taxation of compressors maintained in Ector County that were leased to customers in Sterling and Irion Counties. J-W Power filed motions to correct the appraisal rolls under section 25.25(c) of the Tax Code, arguing that the appraisal rolls included “property that does not exist in the form or at the location described in the appraisal roll.” The Appraisal Review Boards (ARBs) in both counties denied the motions, leading to the current lawsuits.Previously, the district court granted summary judgment to the appraisal districts, arguing among other things that res judicata barred the section 25.25(c) motions because those motions involved the same subject matter as the prior Chapter 41 protests. The court of appeals affirmed this decision, holding that res judicata barred J-W Power’s section 25.25(c) motions, which raised “nearly verbatim” claims as compared to its prior Chapter 41 protests.However, the Supreme Court of Texas disagreed with the lower courts' decisions. The Supreme Court held that section 25.25(l) of the Tax Code preserved J-W Power’s right to file a section 25.25(c) motion notwithstanding its prior Chapter 41 protests. The court interpreted the phrase “regardless of whether” in section 25.25(l) to mean that a property owner can file a section 25.25(c) motion regardless of whether there was a prior Chapter 41 protest related to the value of the property. Therefore, the Supreme Court reversed the judgments of the court of appeals and remanded the cases for further proceedings. View "J-W POWER COMPANY v. IRION COUNTY APPRAISAL DISTRICT" on Justia Law

The Supreme Court of Texas reviewed a case involving Samson Exploration, LLC and several families, including the Bordages, from whom Samson held oil-and-gas leases. The families sued Samson for unpaid royalties under those leases. The Bordages claimed that they were entitled to late charges on the late charges, arguing that the leases' Late Charge Provision imposed late charges on late charges, compounding them each month. Samson disagreed, asserting that the late charges were not compounded.Previously, the trial court found Samson liable for breach of contract and awarded the Bordages $12,955,919 in contract damages, based on the interpretation of the Late Charge Provision. The Bordages argued that collateral estoppel prevented the Supreme Court from deciding whether the Late Charge Provision calls for simple or compound interest because that issue was previously resolved in another case involving Samson and a different lessor, the Hooks case.The Supreme Court of Texas held that Texas law disfavors compound interest, and an agreement for interest on unpaid amounts is an agreement for simple interest absent an express, clear, and specific provision for compound interest. The court also held that Samson’s prior litigation of the issue does not collaterally estop it from asserting its claims here. The court reversed the judgment of the court of appeals and remanded the case to the trial court for further proceedings. View "SAMSON EXPLORATION, LLC v. BORDAGES" on Justia Law

A nuisance lawsuit was brought by neighbors against two poultry farms located on a single tract of rural land in Henderson County, southeast of Dallas. The neighbors claimed that the odors from the farms were a nuisance, causing them discomfort and annoyance. A jury found that the odors were a temporary nuisance and the trial court granted permanent injunctive relief that effectively shut down the farms. The farm owners and operators appealed, challenging the injunction on three grounds: whether the trial court abused its discretion in finding imminent harm; whether equitable relief was unavailable because damages provide an adequate remedy; and whether the scope of the injunction is overly broad.The Supreme Court of Texas upheld the trial court’s authority to grant an injunction, rejecting the first two challenges. However, the court concluded that the trial court abused its discretion in crafting the scope of the injunction, which was broader than necessary to abate the nuisance. The court therefore reversed in part and remanded for the trial court to modify the scope of injunctive relief. View "HUYNH v. BLANCHARD" on Justia Law

The Supreme Court of Texas reviewed a case involving the State of Texas, Ken Paxton in his official capacity as Attorney General of Texas, the Texas Medical Board, and Stephen Brint Carlton in his official capacity as Executive Director of the Texas Medical Board (collectively, the State) against a group of women and physicians. The plaintiffs challenged the constitutionality of Texas's abortion laws, specifically the Human Life Protection Act, which generally prohibits performing an abortion except when a pregnant woman has a life-threatening physical condition that poses a risk of death or serious physical impairment unless an abortion is performed.The case reached the Supreme Court of Texas as a direct appeal from a temporary injunction issued by the 353rd District Court, Travis County, Texas, which halted the enforcement of Texas's abortion laws in various circumstances. The State contested the injunction, arguing that the plaintiffs lacked standing, the State had sovereign immunity, and the current Texas law permitting life-saving abortion was not more limiting than the Texas Constitution permits.The Supreme Court of Texas held that one of the plaintiffs, Dr. Damla Karsan, had standing to challenge the Attorney General’s enforcement of the Human Life Protection Act against her. The court also concluded that the Declaratory Judgments Act waives the State’s immunity for a claim that a statute violates the state constitution. The court further clarified that under the Human Life Protection Act, a woman with a life-threatening physical condition and her physician have the legal authority to proceed with an abortion to save the woman’s life or major bodily function, in the exercise of reasonable medical judgment and with the woman’s informed consent. The court concluded that Dr. Karsan had not demonstrated that the part of the Human Life Protection Act that permits life-saving abortion is narrower than the Texas Constitution allows. As a result, the court vacated the lower court's injunction order. View "State v. Zurawski" on Justia Law