In Bradford v. Vento, the Ventos sued Bruce Bradford, Simon Property Group, and Golden Ring Mall Company for fraud, tortious interference with prospective contractual relations, intentional infliction of emotional distress, DTPA violations, and civil conspiracy after their attempt to purchase a sports memorabilia store in a Texas mall was disrupted by disputes over lease ownership and store access. The trial court entered judgment on a jury verdict awarding the Ventos substantial actual and exemplary damages, which the court of appeals largely affirmed with some reductions. The Texas Supreme Court reversed, holding that no legally sufficient evidence supported any of the liability findings against the defendants. The Court reasoned that Bradford's statements and actions did not constitute fraud or extreme conduct, there was insufficient proof of interference or conspiracy, and the DTPA claim failed for lack of evidence of unfair practices.
The case involved Tammy White suing the Texas Natural Resource Conservation Commission (TNRCC) for property damage from a fire that destroyed her business, which she alleged was caused by gasoline fumes migrating onto her property after the TNRCC installed and then removed a motor-driven pump to dissipate fumes from leaking underground tanks. The TNRCC moved to dismiss for lack of jurisdiction, asserting sovereign immunity under the Texas Tort Claims Act because the pump was not motor-driven equipment and its operation or use did not cause the damage. The trial court and court of appeals denied the motion, but the Supreme Court of Texas held that although the pump qualified as motor-driven equipment under section 101.021, the fire occurred six days after the pump's removal and thus was not proximately caused by its operation or use. The Court therefore reversed and rendered judgment dismissing the case for lack of subject-matter jurisdiction.
The case involved Rhonda Bonner, who was injured by an uninsured motorist and sought uninsured motorist (UM) benefits from Allstate after already receiving personal injury protection (PIP) payments under the same policy. Allstate failed to timely acknowledge her UM claim as required by Texas Insurance Code article 21.55 but denied the claim because the prior PIP payments exceeded the jury's $1,000 UM damages award under the policy's nonduplication provision; the trial court entered a take-nothing judgment on the benefits and denied attorney's fees. The court of appeals affirmed the take-nothing judgment but awarded fees based on the acknowledgment violation. The Texas Supreme Court reversed the fee award, holding that section 6 penalties apply only when the insurer is liable on the claim, which Allstate was not here because the PIP offset defeated any UM recovery.
In Spradlin v. Jim Walter Homes, Inc., the case involved a dispute over the validity of a mechanic's lien on a homestead for the construction of a new home under the Texas Constitution. William Spradlin sought to invalidate the lien held by Jim Walter Homes because it did not comply with procedural requirements in Article XVI, Section 50(a)(5)(A)-(D), such as a cooling-off period and execution at a third-party office. The court decided that these protections apply only to work and material for repairing or renovating existing improvements, not to constructing new improvements, and thus upheld the lien's validity. The core reasoning was a plain-language interpretation of the constitutional text, using the doctrine of last antecedent to limit the subparts to the immediately preceding phrase about existing improvements, supported by the disjunctive "or" separating the two types of work.
This case involved a nursing home negligence and gross negligence suit brought by a resident's estate against Horizon/CMS Healthcare, resulting in a jury verdict of over $2 million in actual damages and $90 million in punitive damages. The Texas Supreme Court held that punitive damages awards in health-care-liability claims are capped by Texas Civil Practice and Remedies Code section 41.007 (limiting them to four times actual damages), not by Texas Revised Civil Statutes article 4590i section 11.02(a), and that article 4590i does cap prejudgment interest on damages falling under its limit. The court reasoned from the plain language and distinct purposes of the two statutes that section 41.007 specifically governs exemplary damages while article 4590i applies to certain actual damages and related interest, and it affirmed the lower court's rulings on other issues such as constitutionality while remanding for recalculation of interest.
This case involved whether Continental Casualty Insurance Co. could obtain judicial review of a Texas Workers' Compensation Commission Hearings Division decision ordering it to pay for medical treatments provided to an injured worker by Functional Restoration Associates and PRIDE after the carrier denied preauthorization. The trial court dismissed the suit for lack of jurisdiction, the court of appeals reversed on the ground of an inherent right to review, and the Texas Supreme Court reversed the court of appeals and affirmed the dismissal. The Court reasoned that the Workers' Compensation Act provides no statutory right to judicial review of medical benefits disputes resolved under Chapter 413, in contrast to other benefit disputes, and that Continental had not adequately pleaded a constitutional due process claim for inherent review. The opinion examined the separate medical dispute resolution procedures in the Act and concluded they do not authorize court review of final hearing officer decisions.