This Texas Supreme Court case arose from a medical malpractice lawsuit brought by Margaret Young against cardiologist Dr. Venkateswarlu Thota and his practice after her husband Ronnie suffered severe complications, including a torn iliac artery, massive bleeding, and eventual death from leukemia, allegedly due to negligence during a coronary catheterization procedure. The jury found no negligence by Dr. Thota, but the court of appeals reversed based on alleged errors in the jury charge, including submission of contributory negligence and a new-and-independent-cause instruction. The Supreme Court held that its presumed-harm analysis from Crown Life Ins. Co. v. Casteel does not apply to broad-form submissions in single-theory-of-liability cases and that any charge errors were harmless under traditional harm review because the evidence supported a finding of no breach of the standard of care. The Court therefore reversed the appellate judgment and remanded for consideration of Young's remaining issues.
The case involved restaurant tenants who signed a lease for a building after the landlord's agent represented it had no problems, but later discovered a severe persistent sewer gas odor from prior tenants that made the space unusable. The tenants sued for rescission and damages based on fraudulent inducement and breach of the implied warranty of suitability, while the landlord contended that merger and disclaimer clauses in the lease barred reliance on any prior statements. The Texas Supreme Court held that the lease language was a standard merger clause that did not disclaim reliance on representations, so it did not negate an element of the fraud claim and could not bar the suit. The court reversed the take-nothing judgment and remanded, while also rendering judgment for the tenants on rescission for breach of the implied warranty.
This case arose from an oil and gas lessor's attempt to recover unpaid royalties from an investor who had consented to drilling operations under a Working Interest Unit Agreement and Joint Operating Agreement but had not operated the wells. The Texas Supreme Court addressed certified questions from the Fifth Circuit, focusing on whether the lessor could enforce those agreements as a third-party beneficiary or through privity of estate. The court held that the lessor had no such right of enforcement. Its reasoning centered on the absence of clear, assumptive language in the agreements by which the investor would directly assume or become liable for the lessor's royalty obligations, and on the fact that the investor's temporary non-consent interest did not create permanent privity or beneficiary status.
In Transcontinental Insurance Co. v. Crump, the case concerned a workers' compensation death benefits claim by the widow of an employee who suffered a knee injury at work and later died from complications, with the insurer disputing whether the injury was a producing cause of death. The Texas Supreme Court held that the treating physician's differential diagnosis constituted reliable expert testimony that was legally sufficient to support the jury verdict on causation, but the trial court's jury instruction defining producing cause was erroneous for omitting the but-for component, and the insurer was entitled to a jury trial on the disputed amount of the claimant's attorney's fees. The court reasoned from precedent that producing cause requires both a substantial factor and but-for causation, that the expert opinion rested on a reliable foundation, and that Labor Code section 408.221(c) mandates jury determination of fees when disputed. The judgment was reversed and the case remanded for a new trial.
In this case, plaintiff Barry Joachim sued his insurer Travelers for underinsured motorist benefits but filed a nonsuit the day before trial; the trial court later entered an erroneous dismissal with prejudice for want of prosecution. Joachim refiled the same claims in a new proceeding, where the second trial court granted summary judgment to Travelers on res judicata grounds. The court of appeals reversed, holding the first dismissal order void because the nonsuit had already deprived the court of jurisdiction. The Texas Supreme Court reversed that holding, concluding that the first court’s order was merely voidable rather than void, constituted a final judgment on the merits by a court of competent jurisdiction, and therefore barred the second suit under res judicata.
This case involved business partners Larry Snodgrass and J. Mark Swinnea, who owned equal interests in ERI Consulting Engineers and Malmeba Company. Swinnea fraudulently induced Snodgrass and ERI to buy out his interest in ERI while secretly setting up a competing asbestos abatement business through family members, without disclosure, and later competed in ways that harmed ERI's relationships and profits, leading to findings of statutory fraud, common law fraud, breach of non-compete, and breach of fiduciary duty after a bench trial. The trial court awarded damages including equitable forfeiture of part of the buyout consideration plus lost profits, but the court of appeals reversed, holding forfeiture unavailable. The Supreme Court of Texas reversed in part, holding that consideration received for a business interest sale is subject to equitable forfeiture as a remedy for breach of fiduciary duty by fraudulent inducement of the buyout, in addition to other resulting damages, and remanded for further proceedings.