The case concerned the University of Texas at Austin's refusal to disclose final results of student disciplinary hearings involving sex offenses in response to a request from the Austin American-Statesman newspaper. The University argued it could withhold the records under the Texas Public Information Act without seeking an opinion from the Office of the Attorney General because the federal Family Educational Rights and Privacy Act (FERPA) protects such education records. The Texas Supreme Court held that the PIA authorized the University's refusal without an OAG decision and that the trial court should have granted summary judgment to the University. The core reasoning was that FERPA conditions federal funding on protecting student disciplinary records, PIA Section 552.114 allows withholding without an OAG opinion in these circumstances, and federal guidance confirms the OAG would decline to review such records anyway.
This case involves a legal malpractice claim brought by Henry S. Miller Commercial Company against its former lawyers, Newsom, Terry & Newsom, LLP and Steven K. Terry, stemming from an underlying real estate dispute that Miller lost. The Texas Supreme Court addressed whether Miller's claim was barred because the underlying opponent had obtained an interest in the malpractice recovery or influenced the litigation, requiring a reversal of positions about the strength of the cases. The Court held that the claim was not barred like an assignment would be, because Miller retained substantial control over the claim, though juries must be informed of any such interests or influences; it also ruled there was evidence of some negligence damages but none supporting the full jury award or gross negligence. The Court therefore affirmed remand for a new trial on the negligence claim only and rendered judgment against the gross negligence claim.
The case In re J.Y.O. involved the division of marital assets following the 2019 divorce of Hakan and Lauren Oksuzler, specifically addressing a discretionary bonus paid to Hakan in February 2020 for his 2019 work at Bank of America, ownership interests in the marital home after refinancing, and the proper characterization of funds in Hakan's 401(k) account. The Supreme Court of Texas held that the bonus constituted community property because it was compensation for services performed during the marriage, reversing the court of appeals on that issue. The court affirmed that the refinancing deed gave rise to an unrebutted gift presumption, requiring each spouse to receive an undivided one-half interest in the home as tenants in common. It also affirmed the remand of the 401(k) issue for proper tracing of premarital separate contributions versus marital community contributions, as the trial court's calculation lacked sufficient evidence.
The case involved the Texas Department of Public Safety's suspension of Stephen Caruana's driver's license after a breath test showed alcohol concentration above the legal limit following his arrest for driving while intoxicated. At the administrative hearing, the arresting officer's report was admitted into evidence despite not being sworn as required by statute, and the ALJ upheld the suspension based on the report and test results. The county court and court of appeals reversed, holding the unsworn report inadmissible under evidence rules and SOAH regulations. The Texas Supreme Court reversed those decisions, ruling that the report was admissible under Texas Rule of Evidence 803(8) as a public record because an officer's failure to swear does not undermine its reliability, given that false statements in governmental records are also criminal offenses.
This case involved a pay dispute between the City of Dallas and its police officers and firefighters over a 1979 ordinance, adopted by voter referendum, that provided a 15% raise and required maintaining percentage pay differentials between ranks. The officers sued for a declaratory judgment interpreting the ordinance and damages for breach of their employment contracts, claiming the City failed to maintain the differentials when giving raises to higher ranks. The City asserted governmental immunity from suit, nonsuited its own counterclaim for alleged overpayments, and the case reached the Texas Supreme Court on an interlocutory appeal after the trial court denied immunity. The Court held that the City's nonsuit of its counterclaim did not restore full immunity, that the case must be remanded to address a new legislative waiver of immunity, that the City retained immunity from the declaratory judgment claim, and that adoption of the ordinance by referendum did not waive the City's immunity because the officers were not acting in a legislative capacity.
The case concerned whether two state hospital doctors, sued along with their employer on health care liability claims, could pursue an interlocutory appeal from the denial of their motions to dismiss under section 101.106(e) of the Texas Tort Claims Act, which requires immediate dismissal of employees when the governmental unit moves for it. After the plaintiff nonsuited the hospital, the trial court denied the doctors' motions, and the court of appeals dismissed the appeal for lack of jurisdiction under section 51.014(a), holding that a motion to dismiss is neither a motion for summary judgment nor a plea to the jurisdiction. The Texas Supreme Court reversed, holding that an interlocutory appeal lies from the denial of a motion asserting the statutory right to dismissal regardless of the procedural vehicle used, because the statute's purpose is to permit review of the immunity issue itself; it further held that the nonsuit could not defeat the doctors' pending claim for affirmative relief under the Act.
