Justia Constitutional Law Opinion Summaries

The case involves successors in interest of mineral-rights holders who sued in 2019 to declare a 1999 judgment foreclosing on their predecessors’ property for delinquent taxes as void. They argued that there was constitutionally inadequate notice of the foreclosure suit, rendering the foreclosure judgment and the tax sale that followed both void. The current owners sought traditional summary judgment based on the Tax Code’s command that an action relating to the title to property against the purchaser of the property at a tax sale may not be commenced later than one year after the date that the deed executed to the purchaser at the tax sale is filed of record.The trial court granted the current owners' motion for summary judgment, and the court of appeals affirmed. The majority held that the sheriff’s deed conclusively established the accrual date for limitations, so the burden shifted to the successors to adduce evidence raising a genuine issue of material fact as to whether there was a due-process violation that could render the statute of limitations inoperable. Because the successors relied only on their arguments and presented no evidence of a due-process violation, the majority concluded, the current owners were entitled to summary judgment.The Supreme Court of Texas held that under Draughon v. Johnson, the nonmovant seeking to avoid the limitations bar by raising a due-process challenge bears the burden to adduce evidence raising a genuine issue of material fact about whether the underlying judgment is actually void for lack of due process. Because the nonmovant here adduced no such evidence, the trial court correctly granted summary judgment based on Section 33.54(a)(1). However, the court also noted that the law governing this case has undergone meaningful refinement since the summary-judgment proceedings took place. Given these recent and substantial developments in the relevant law, the court remanded this case to the trial court for further proceedings in the interest of justice. View "GILL v. HILL" on Justia Law

The case before the Supreme Court of Texas concerned the City of Dallas and the Employees’ Retirement Fund of the City of Dallas. The issue at hand was whether a city ordinance could confer a third party the perpetual right to veto categories of future lawmaking. The Court of Appeals held that the City of Dallas could not amend Chapter 40A of its code of ordinances unless the board of trustees of the Employees’ Retirement Fund agreed to the amendment. However, the Supreme Court of Texas found that such delegation of lawmaking authority was not permissible.The Supreme Court of Texas based its ruling on the principle that a legislative body cannot bind its successors, and on the constitutional principle forbidding the city council from giving away its authority to legislate. The court determined that the board’s veto in § 40A-35(a) was unenforceable and cannot prevent an otherwise valid ordinance from taking effect.However, the court did not resolve whether the City must hold an election that submits § 8-1.5(a-1) to the voters before it can enforce that provision. The court declined to address this question and remanded the case back to the Court of Appeals for further consideration. View "THE CITY OF DALLAS v. THE EMPLOYEES' RETIREMENT FUND OF THE CITY OF DALLAS" on Justia Law

In this case handled by the Supreme Court of Texas, the parents of two children, Kate Cox and Justin Cox, along with their doctor, Dr. Damla Karsan, filed a suit to challenge the enforcement of Texas laws that prohibit abortion. Mrs. Cox was about 20 weeks pregnant with a baby diagnosed with trisomy 18, a serious genetic disorder. The suit sought to apply a medical-necessity exception provided in the Texas law, which allows an abortion if a woman's life is threatened or she faces a serious risk of substantial impairment of a major bodily function due to her pregnancy.The court, in its decision, clarified that the exception to the abortion prohibition is based on the reasonable medical judgment of a doctor, not a court. It was noted that Dr. Karsan presented a "good faith belief" that Mrs. Cox meets the exception's requirements but did not assert that her belief meets the objective standard of "reasonable medical judgment."The court held that judges lack the authority to broaden the statutory exception by interpreting it and held the trial court erred in applying a different, lower standard instead of requiring reasonable medical judgment. The court emphasized that the exception requires a doctor's decision whether a pregnant woman’s complications pose the required risks.The court conditionally granted relief and directed the trial court to vacate the temporary restraining order that had restrained the Attorney General from enforcing the abortion laws against Dr. Karsan and others related to the case, based solely on the verified pleading. The court also noted that nothing in their opinion prevents a physician from acting if, in that physician’s reasonable medical judgment, they determine that the pregnant woman has a life-threatening physical condition. View "IN RE STATE OF TEXAS" on Justia Law

The Supreme Court vacated the judgment of the court of appeals affirming the trial court's judgment issuing in July 2021 a temporary restraining order prohibiting enforcement of executive order GA-38, holding that this case is remanded for further proceedings consistent with this Court's opinion in Abbott v. Harris County, 22-0124, which concerned the scope and constitutionality of the Governor's authority under the Disaster Act to prohibit local governments from imposing mask requirements.The City of San Antonio and Bexar County jointly filed this lawsuit challenging GA-38, which prohibited local officials from requiring masks in response to the coronavirus epidemic. The district court issued a temporary restraining order prohibiting enforcement of the executive order and then temporarily enjoined the Governor and others from enforcing GA-38 to the extent that such a requirement would interfere with the local official's authority to require masks in government-owed buildings and schools. The court of appeals affirmed the temporary injunction. In light of this Court's decision in Abbott v. Harris County, the Supreme Court vacated the judgment below, holding that remand was required. View "Abbott v. City of San Antonio" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals in this products-liability case concluding that the exercise of personal jurisdiction over Defendants was consistent with due process, holding that the minimum-contacts analysis requires evaluation of a defendant's contacts with the forum - Texas - as a whole.Plaintiff was injured when he used a lithium-ion battery that he bought at a store in Texas and used it to charge his e-cigarette. Although Defendants sold and distributed the batteries to manufacturers in Texas they argued that Texas courts lacked personal jurisdiction because they did not send the batteries to Texas for resale to individual consumers to use with e-cigarettes. Specifically, Defendants argued that Plaintiff's claims arose out of the use of the battery in a way Defendants never intended by an individual consumer they never targeted. The lower courts concluded that the exercise of personal jurisdiction over Defendants was consistent with due process. The Supreme Court affirmed, holding that the relatedness prong of the minimum-contacts analysis does not require that the plaintiff's claims arose out of a set of facts mirroring the defendant's expectations about the course its product would follow after entering the state of Texas. View "LG Chem America, Inc. v. Morgan" on Justia Law

The Supreme Court reversed the judgment of the court of appeals on a survival claim brought by the estate of Clark Davis against United Rentals North America, Inc., rendered a take nothing judgment on this claim, and remanded the case to the district court for a new trial on the remaining claims, holding that racial considerations impermissibly tainted the selection of the jury in the underlying trial.During jury selection, Plaintiffs' counsel stated that "the African-American female was the most favorable juror in this case," and this announced preference was consistent with Plaintiffs' peremptory strikes. The jury returned a verdict for Plaintiffs, and the district court awarded $5 million to Davis's estate. The court of appeals affirmed. The Supreme Court reversed, holding that a new trial was required because counsel stated a racial preference in jury selection, the peremptory strikes were consistent with that preference, and the district court did not remedy the issue. View "United Rentals North America, Inc. v. Evans" on Justia Law

In this "highly unusual" personal jurisdiction dispute the Supreme Court held that Texas courts have specific jurisdiction over German automobile manufacturers based on their intentional post-sale tampering with affected vehicles that were owned, operated, and serviced in Texas.The State and several local governments brought civil actions to enforce state environmental laws against Defendants - German automobile manufacturers that intentionally evaded federal emissions standards by embedding illegal emissions-defeating technology in graded vehicles. At issue was whether the manufacturers' contacts with Texas satisfied the constitutional requisites to exercising specific personal jurisdiction. The trial court ruled that the manufacturers were amenable to specific personal jurisdiction in Texas, but the court of appeals reversed. The Supreme Court reversed, holding that where the manufacturers developed the product, controlled the distribution stream that brought the product to Texas, and "called all the shots," the trial court did not err in exercising specific personal jurisdiction over the German manufacturers. View "State v. Volkswagen Aktiengesellschaft" on Justia Law

The Supreme Court held that a claimant alleging wrongful imprisonment against state government entities and employees may not maintain such a suit once the claimant has received Tim Cole Act compensation through the state administrative process.Plaintiff was imprisoned for about twelve years, most of them on death row, until his conviction was vacated on the ground that the prosecutor had failed to disclose exculpatory evidence during his criminal trial. Plaintiff brought suit in federal court under 42 U.S.C. 1983, alleging that various state government entities and employees had violated his constitutional rights. Based on the results of an independent investigation, the district court dismissed Plaintiff's charges on the grounds that Plaintiff was actually innocent. Plaintiff was subsequently granted compensation under the Tim Cole Act. The district court granted Defendants' motion to dismiss Plaintiff's federal case, concluding that Plaintiff's recent of compensation from the state foreclosed his suit. On appeal, the federal district court certified a question to the Supreme Court. The Supreme Court answered that Plaintiff's acceptance of the Tim Cole Act compensation barred maintenance of this lawsuit. View "Brown v. City of Houston, Texas" on Justia Law

The Supreme Court reversed the order of the trial court dismissing the claims brought by the Mexican American Legislative Caucus (MALC) and the claim brought by a group of plaintiffs referred to as the Gutierrez Plaintiffs that the recently enacted laws reapportioning Texas's legislative districts violate Tex. Const. art. III, 26, holding that the trial court erred in part.MALC and the Gutierrez Plaintiffs sued Defendants - various State officials - claiming that the laws at issue violated Article III, Sections 26 and 28. Defendants filed pleas to the jurisdiction, which the trial court largely denied. The Supreme Court reversed in part and remanded the case to the trial court, holding (1) MALC lacked associational standing to pursue its claims; (2) at least one of the Gutierrez Plaintiffs had standing to pursue each claim a proper defendant, but not the State; (3) the Gutierrez Plaintiffs' section 26 was not barred by sovereign immunity, but the section 28 claim was; and (4) the Gutierrez Plaintiffs should have the opportunity to replead their section 26 claim against a proper defendant. View "Abbott v. Mexican American Legislative Caucus" on Justia Law

The Supreme Court reversed the judgment of the trial court permanently enjoining the Texas Department of State Health Services from enforcing a new Texas law that prohibited the processing and manufacturing of smokable hemp products, holding that Plaintiffs were not entitled to relief.In their complaint, Plaintiffs - Texas-based entities that manufacture, process, distribute, and sell hemp products - argued that Tex. Const. art. I, 19 invalidated the challenged law and sought an injunction prohibiting Defendant from enforcing the law. The trial court declared that Tex. Health & Safety Code 443.202(4) violated the Texas Constitution and that 25 Tex. Admin. Code 300.104 was invalid in its entirety and enjoined Defendant from enforcing the statute or the rule. The Supreme Court reversed, holding that Plaintiffs' complaints did not assert the deprivation of an interest substantively protected by the Texas Constitution's due course clause. View "Texas Department of State Health Services v. Crown Distributing LLC" on Justia Law