The case involved a dispute between Cactus Water Services, a surface-estate lessee claiming rights to produced water from oil and gas wells, and COG Operating, the hydrocarbon lessee, over ownership of produced water not explicitly addressed in the oil-and-gas leases. The Texas Supreme Court held that the right to produced water belongs to the hydrocarbon lessee as part of the oil-and-gas conveyance. The court's reasoning was that produced water is an inherent byproduct of hydrocarbon production, and under longstanding Texas law and industry practice, the conveyance of oil-and-gas rights includes the incidental right to dispose of this waste, which consumes any value in the water molecules; surface owners must expressly reserve such rights if they wish to retain them, and subsequent technological developments do not alter the original conveyances.
The case involved Rita Oteka, a university faculty member, who was injured by a campus police officer's vehicle while attending a commencement ceremony and sued the University of Texas Rio Grande Valley for negligence after declining workers' compensation benefits. The University raised the exclusive-remedy defense under the Texas workers' compensation system, asserting that the injury was work-related and thus barred the lawsuit. The Supreme Court of Texas held that the Division of Workers’ Compensation lacks exclusive jurisdiction to decide whether the injury occurred in the course and scope of employment when the employee is not pursuing benefits and the claim does not depend on compensability determinations. The court reasoned that the Legislature preserved district court jurisdiction over such disputes arising outside the benefits context, affirming the court of appeals' judgment that the trial court could proceed.
This case arose from a shooting at a Home Depot store in which a suspected shoplifter killed one police officer and injured another after the officers responded to a request from an off-duty officer working as the store's security guard. The decedent's family and the injured officer sued the security guard, Home Depot, and the security company for wrongful death, survival, and personal injury. The Texas Supreme Court held that the off-duty officer's conduct was within the scope of his governmental employment because he had a statutory duty to prevent the theft, entitling him to dismissal under the Tort Claims Act. The Court also adopted the public-safety officer's rule, which limits the duties owed to officers injured by the negligence that prompted their response, and applied it to grant summary judgment for Home Depot and the security company. The Court reversed the court of appeals and reinstated the trial court's judgment dismissing the claims.
The case involved property owners in the City of College Station's extraterritorial jurisdiction challenging city ordinances regulating off-premise signs and driveways, arguing that such regulation without voting rights violates the Texas Constitution's requirement for a republican form of government. The lower courts dismissed the suit as nonjusticiable, but while on appeal, the legislature enacted a law allowing ETJ residents to opt out of city jurisdiction unilaterally. The Supreme Court of Texas vacated the lower court judgments and remanded with instructions to abate the case to give the plaintiffs time to pursue the statutory opt-out remedy, which would moot their constitutional claims, in order to avoid unnecessary constitutional adjudication.
This Texas Supreme Court case involved a dispute over underinsured motorist (UIM) coverage after an insured sued her insurer, State Farm, for declaratory relief on liability and damages from a car accident, plus extracontractual claims under the Insurance Code. The insured sought discovery on the extracontractual claims and a deposition of the insurer's corporate representative before resolving the underlying UIM entitlement in a bifurcated proceeding. The Court held that the trial court abused its discretion by denying the insurer's motions to abate the extracontractual claims and quash the deposition while the UIM claims remained pending. It reasoned that UIM benefits require a prior judgment establishing the tortfeasor's liability and the insured's damages, that extracontractual claims depend on that determination and may become moot, and that the requested discovery was improper and not proportional at this stage since the insurer had produced relevant documents and lacked personal knowledge of the crash issues.
The case concerned whether the Texas Commission on Environmental Quality properly granted the City of Dripping Springs a permit to discharge treated wastewater into Onion Creek under the agency's antidegradation rules, which prohibit lowering water quality by more than a de minimis extent for high-quality waters. Save Our Springs Alliance argued that the rules require a strict parameter-by-parameter analysis and that a predicted drop in dissolved oxygen levels violated the standards, and also that the agency's order lacked required statements of underlying facts under the Administrative Procedure Act. The Supreme Court of Texas affirmed the court of appeals' judgment upholding the permit. It held that the agency's practice of evaluating overall water-body quality rather than isolated numeric changes to individual parameters complies with the written rules, and that no additional fact findings were needed because the order adequately stated the basis for the decision and the governing statutes do not mandate parameter-specific findings.
The case involved a lawsuit by Ruben Rodriguez and Frederick Okon against the City of Houston for personal injuries sustained when a police officer's patrol car struck their pickup truck during a high-speed pursuit of a suspected felon in a stolen vehicle. The trial court denied the city's motion for summary judgment based on official immunity and the emergency exception under the Texas Tort Claims Act, and the court of appeals affirmed. The Supreme Court of Texas reversed, holding that the officer was acting in good faith as a matter of law because his testimony did not indicate prior knowledge of defective brakes, and the plaintiffs failed to raise a fact issue controverting the city's evidence of good faith. Therefore, official immunity shielded the officer from personal liability, preventing waiver of the city's governmental immunity, and the court rendered judgment dismissing the case.