Justia Contracts Opinion Summaries

Articles Posted in Supreme Court of Texas
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The Supreme Court conditionally granted relief in this mandamus proceeding concerning a premarital agreement to resolve disputes by binding arbitration under religious law, holding that the trial court erred by ordering arbitration before determining whether the agreement was valid and enforceable, as required by Tex. Fam. Code 6.6015 and 153.00715.In 2008 the parties married. In connection with their marriage, they signed a document entitled "Islamic Pre-Nuptial Agreement" providing that conflicts arising between the parties would be resolved according to Islamic law in a Muslim court or a three-person panel. After Wife sued for divorce, Husband moved to enforce the agreement. The trial court stayed proceedings pending arbitration, and the court of appeals denied Wife's request for mandamus relief. The Supreme Court conditionally granted relief, holding that the trial court erred in ordering arbitration without first determining the validity and enforceability of the agreement. View "In re Ayad" on Justia Law

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The Supreme Court held that the application the Fair Practices of Equipment Manufacturers, Distributors, Wholesalers, and Dealers Act, Tex. Bus. & Com. Code 57.001-.402, in this case did not violate the constitutional prohibition against retroactive laws in Tex. Const. art. I, 16.In the 1990s, Fire Protection Service, Inc. (FPS), orally agreed to be an authorized dealer and servicer of the life rafts manufactured by Survitec Survival Products, Inc. Nearly six years after the promulgation of the Act, which prohibits a supplier from terminating a dealer agreement without good cause, Survitec notified FPS that it was terminating their relationship. FPS sued for a violation of the Act. The district court entered judgment for Survitec. On appeal, the Fifth Circuit certified a question to the Supreme Court. The Supreme Court answered that the application of the Act to the parties' agreement does not violate the retroactivity clause in article I, section 16. View "Fire Protection Service, Inc. v. Survitec Survival Products, Inc." on Justia Law

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The Supreme Court reversed the judgment of the court of appeals concluding that the "procuring-cause doctrine" did not apply to the facts of this case, holding that the procuring-cause doctrine applied to the parties' contractual relationship.If a seller agrees to pay sales commissions to a broker or other agent and their contract says nothing more than that commissions will be paid for sales, Texas law applies a default rule called the procuring-cause doctrine. When the seller refused to pay the broker in this case commissions on sales that were finalized after his termination, the broker sued the seller for breach of contract. The jury found for the broker. The court of appeals affirmed. The Supreme Court reversed and remanded the case for further proceedings, holding that the procuring-cause doctrine applied to the contractual relationship in this case. View "Pesthuis v. Baylor Miraca Genetics Laboratories, LLC" on Justia Law

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In this case arising out of a construction contract dispute involving competing claims of breach between the owner and the contractor, the Supreme Court reversed in part the court of appeals' judgment affirming the portion of the trial court's judgment awarding damages to the owner but reversing as to the contractor, holding that the judgment awarding certain expenses to the owner could not stand.The jury found that both the owner and the contractor breached the contract and awarded damages as to both parties. At issue was whether the owner's entitlement to recover contract damages associated with a termination of the contractor for default hinged on strict compliance with the written-notice conditions precedent to such recovery, whether sufficient evidence supported the jury's finding of compliance, and whether a contractual provision governing consequential damages was liability waiver or a covenant not to sue. The Supreme Court held (1) when a contract mandates written notice, a writing is a necessary part of complying with contractual notice conditions, substantially or otherwise; (2) because the owner failed to provide the requisite written notices to be entitled to recover expenses associated with a termination for default, the judgment awarding them to the owner could not stand; and (3) the contract did not contain a covenant not to sue for consequential damages. View "James Construction Group, LLC v. Westlake Chemical Corp." on Justia Law

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The Supreme Court reversed the decision of the court of appeals affirming in part and reversing in part the judgment of the trial court holding that the settlement agreement between the parties in this case barred the claims asserted in this suit and in an arbitration proceeding, holding that the trial court did not err.A billion-dollar break-up between two large corporations engaged in the international petroleum business resulted in numerous claims and lawsuits, which the parties finally resolved through a comprehensive settlement agreement. The trial court concluded that the settlement agreement, including its release provisions and a disclaimer of reliance, were valid and enforceable and barred the claims asserted in both this lawsuit and in the arbitration proceeding. The court of appeals reversed in part, concluding that the settlement agreement did not bar certain claims. The Supreme Court reversed and reinstated the final judgment of the trial court, holding that the parties fully and finally resolved the current claims through their comprehensive settlement agreement. View "Transcor Astra Group S.A. v. Petrobras America Inc." on Justia Law

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The Supreme Court reversed the judgment of the court of appeals as to attorney's fees in this case concerning whether Defendant, a condominium association, was entitled to attorney's fees after obtaining a take-nothing judgment on claims by Plaintiff, a unit owner, the Supreme Court held that the fee award was authorized by Tex. Prop. Code 82.161(b).Plaintiff sued Defendant for, among other things, fraud, civil conspiracy, breach of contract, and negligence. Defendant filed a counterclaim for declaratory judgment and requested attorney's fees. The trial court granted Defendant's motion on twelve declaratory issues. After a trial, the court granted judgment for Defendant and awarded attorney's fees. The court of appeals affirmed the judgment for Defendant but reversed the award of attorney's fees. The Supreme Court reversed in part, holding that Defendant was a prevailing party under Tex. Prop. Code 82.161(b) and was thus entitled to reasonable attorney's fees. View "Sunchase IV Homeowners Ass'n v. Atkinson" on Justia Law

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The Supreme Court reversed the judgment of the court of appeals reversing the judgment of the trial court, rendered pursuant to a jury verdict, that Stephen Stelly owned real property free of any encumbrance, holding that Stelly adequately pleaded a trespass-to-try-title claim.Stelly brought this action against John DeLoach claiming that DeLoach had breached the parties' contract by not delivering a real property deed after Stelly had paid off the debt on the land's original purchase price.The jury entered a verdict in favor of Stelly. The court of appeals reversed, concluding that Stelly pleaded only a breach-of-contract claim, not a trespass-to-try-title claim and that the statute of limitations had run on Stelly's breach of contract claim. The Supreme Court reversed and remanded the case for further proceedings, holding that Stelly adequately pleaded a trespass-to-try-title claim. View "Stelly v. DeLoach" on Justia Law

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The Supreme Court reversed the judgment of the court of appeals ruling that the parties' contract in this case and its arbitration provision were unenforceable on the grounds that the parties never had a meeting of the minds on the contract, holding that the parties formed the agreement reflected in the contract they signed.Plaintiffs, members of the family of a woman killed in a high-speed crash while riding in a car driven by an intoxicated adult entertainer employed by Defendant, sued for wrongful death and survival damages, alleging that Defendant continued serving the driver alcohol after knowing she was clearly intoxicated. Defendant moved to compel arbitration pursuant to a contract containing an arbitration provision that the decedent and Defendant had signed almost two years earlier. The trial court denied the motion. The court of appeals affirmed, concluding that the terms in the contract were not perfectly clear, and therefore, there was no meeting of the minds. The Supreme Court reversed, holding that the contract terms were sufficient to constitute an enforceable contract. View "Baby Dolls Topless Saloons, Inc. v. Sotero" on Justia Law

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The Supreme Court reversed the judgment of the court of appeals affirming the decision of the trial court granting summary judgment in favor of Roy Elizondo and dismissing this action brought by Cadence Bank, N.A. for breach of a deposit agreement, breach of warranty under the Uniform Commercial Code (UCC), and common-law torts, holding that the lower courts erred.In response to a stranger's email for legal assistance, Elizondo, an attorney, deposited a cashier's check in his bank account then wired most of the funds to an overseas account. The check was dishonored, and the bank charged the transfer back to Elizondo, as allowed by the UCC and the parties' deposit agreement. When Elizondo refused to pay the overdrawn funds Cadence brought this action. The trial court granted summary judgment for Elizondo, and the court of appeals affirmed. The Supreme Court reversed, holding that the wire-transfer form failed to create the contractual duty urged by Elizondo. View "Cadence Bank, N.A. v. Elizondo" on Justia Law

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The Supreme Court reversed in part the decision of the court of appeals reversing the trial court's summary judgment in this case involving a school district's breach of warranty claims against a general contractor and an artificial-field-turf manufacturer, holding that the court of appeals erred.The Supreme Court reversed in part and reinstated the trial court's summary judgment in favor of the contractor, holding (1) a trial court’s on-the-record, oral ruling sustaining an objection to summary judgment evidence suffices to strike the evidence from the summary judgment record when the ruling is not reduced to a written order; and (2) the court of appeals erred in reversing the trial court's summary judgment in favor of the contractor and remanding the claims against the turf manufacturer for a new trial without addressing the merits of the issues on appeal that could result in rendition of judgment in favor of the manufacturer. View "FieldTurf USA, Inc. v. Pleasant Grove Independent School District" on Justia Law