Justia Government & Administrative Law Opinion Summaries

The case involves Dianne Hensley, a justice of the peace in Texas, who announced that due to her religious beliefs, she would not perform weddings for same-sex couples but would refer them to others who would. The State Commission on Judicial Conduct issued her a public warning for casting doubt on her capacity to act impartially due to the person's sexual orientation, in violation of Canon 4A(1) of the Texas Code of Judicial Conduct. Hensley did not appeal this warning to a Special Court of Review (SCR) but instead sued the Commission and its members and officers for violating the Texas Religious Freedom Restoration Act (TRFRA) and her right to freedom of speech under Article I, Section 8 of the Texas Constitution. The trial court dismissed her claims for lack of jurisdiction, and the court of appeals affirmed.The Supreme Court of Texas held that Hensley's suit was not barred by her decision not to appeal the Commission’s Public Warning or by sovereign immunity. The court affirmed the part of the court of appeals’ judgment dismissing one of Hensley's declaratory requests for lack of jurisdiction, reversed the remainder of the judgment, and remanded to the court of appeals to address the remaining issues on appeal. The court found that the SCR could not have finally decided whether Hensley is entitled to the relief sought in this case or awarded the relief TRFRA provides to successful claimants. View "HENSLEY v. STATE COMMISSION ON JUDICIAL CONDUCT" on Justia Law

The case involves Ammonite Oil & Gas Corporation (Ammonite) and the Railroad Commission of Texas and EOG Resources, Inc. (EOG). Ammonite leases mineral rights beneath a riverbed from the State of Texas. EOG leases the minerals on the land adjoining the river on both sides. All the minerals in the area lie in a common subsurface reservoir. EOG's wells, however, do not reach the minerals beneath the riverbed. Ammonite argued that without pooling, its minerals are left stranded. Ammonite applied to the Railroad Commission for forced pooling under the Texas Mineral Interest Pooling Act (MIPA).The Railroad Commission rejected Ammonite's applications to force-pool the minerals beneath the river—which are not being produced—with those beside it—which are. The lower courts affirmed the Commission’s order. The Supreme Court of Texas also affirmed the lower courts' decisions but for different reasons than the court of appeals gave.The Supreme Court of Texas held that the Commission’s conclusion that “Ammonite failed to make a fair and reasonable offer to voluntarily pool as required by [MIPA Section] 102.013” is reasonable. The court also held that Ammonite has failed to show that forced pooling of its acreage with EOG’s wells is necessary to prevent its minerals from ultimately being lost. The court concluded that Ammonite applied for a share of EOG’s revenue without contributing to it and that the Commission’s conclusion that forced pooling would not prevent waste or protect correlative rights is not unreasonable. View "AMMONITE OIL & GAS CORPORATION v. RAILROAD COMMISSION OF TEXAS" on Justia Law

This case involves a dispute over the interpretation of a statute that regulates healthcare providers participating in the federal Medicaid program. The State of Texas, acting through the Attorney General, sought to enforce a statute that imposes penalties on a provider who submits a claim for payment and knowingly fails to indicate the type of professional license and the identification number of the person who actually provided the service. The defendant, a dentist, argued that the statute only applies if a claim fails to indicate both the license type and the identification number of the actual provider.Previously, the trial court granted the State's motion for partial summary judgment and denied the defendant's motion. The court rendered a final judgment awarding the State more than $16,500,000. The defendant appealed, and the court of appeals affirmed the trial court's judgment, except for the amount of attorney’s fees and expenses.The Supreme Court of Texas reversed the lower courts' decisions. The court agreed with the defendant's interpretation of the statute. The court held that the statute applies only if a claim fails to indicate both the license type and the identification number of the actual provider. The court found that the 1,842 claims at issue did indicate the actual providers’ license type, so they did not constitute an unlawful act under the statute. The court rendered judgment in the dentist’s favor. View "MALOUF v. THE STATE OF TEXAS EX RELS. ELLIS AND CASTILLO" on Justia Law

The case involves Image API, LLC, a company that provided services to the Texas Health and Human Services Commission (HHSC) from 2009 to 2015. Image's job was to manage a processing center for incoming mail related to Medicaid and other benefits programs. The agreement between the parties stated that HHSC would compensate Image using its “retrospective cost settlement model”. In 2016, HHSC notified Image that an independent external firm would conduct an audit of Image’s performance and billing for the years 2010 and 2011. The audit concluded that HHSC had overpaid Image approximately $440,000 in costs relating to bonuses, holiday pay, overtime, and other unauthorized labor expenses. HHSC then sought to recoup the overpayments by deducting from payments on Image’s invoices.The trial court granted HHSC’s motion for summary judgment and signed a final judgment for the commissioner. The court of appeals reversed the trial court’s judgment and dismissed Image’s entire suit for want of jurisdiction. Image sought review.The Supreme Court of Texas held that Image is a Medicaid contractor under Section 32.0705(a), and that the deadline in Section 32.0705(d) for auditing HHSC’s Medicaid contractors is mandatory. However, the court ruled that HHSC’s failure to meet the deadline does not preclude it from using the result of the audit or pursuing recoupment of overcharges found in the audit. The court affirmed the part of the court of appeals’ judgment dismissing Image’s claims arising from the 2016 audit for lack of jurisdiction, reversed the part of the judgment dismissing the remainder of Image’s suit, and remanded to the trial court for further proceedings. View "IMAGE API, LLC v. YOUNG" on Justia Law

The case revolves around a program proposed by Harris County, Texas, known as "Uplift Harris." The program aimed to provide $500 monthly cash payments to 1,928 Harris County residents for 18 months, with recipients chosen by lottery from applicants with income below 200% of the federal poverty line living in certain zip codes. The State of Texas challenged the program, arguing that it violated the Texas Constitution’s prohibition on gratuitous payments to individuals.The State sued the County, seeking an injunction to block the implementation of the program. The district court denied the State's request for a temporary injunction, leading the State to appeal this decision and request a stay of payments under the Uplift Harris program while the appeal was ongoing. The court of appeals denied this request, prompting the State to seek mandamus relief in the Supreme Court of Texas.The Supreme Court of Texas granted the State's motion for temporary relief, prohibiting all payments under the Uplift Harris program pending further order of the court. The court found that the State had raised serious doubt about the constitutionality of the program, and that potential violation of the Texas Constitution could not be remedied if payments were to commence while the underlying appeal proceeded. The court also noted that once the funds were distributed to individuals, they could not feasibly be recouped if it was later determined they were paid in violation of the Texas Constitution. The court concluded that temporarily preventing the expenditure of these funds while the State's appeal proceeded ensured public funds were not irrecoverably spent in violation of the Texas Constitution. The State's appeal of the denial of a temporary injunction remains pending in the court of appeals. View "In re The State of Texas" on Justia Law

The case revolves around the Public Utility Commission of Texas (PUC) and two market participants, RWE Renewables Americas, LLC and TX Hereford Wind, LLC. Following Winter Storm Uri, the Legislature amended the Public Utility Regulatory Act (PURA) to require that protocols adopted by the Electric Reliability Council of Texas (ERCOT) must be approved by the PUC before they take effect. ERCOT then adopted a revision to its protocols, which was approved by the PUC, setting the price of electricity at the regulatory maximum under Energy Emergency Alert Level 3 conditions. RWE challenged the PUC's approval order in the Third Court of Appeals, arguing that the order was both substantively and procedurally invalid.The Third Court of Appeals held that the PUC's order was both substantively invalid—because the PUC exceeded its statutory authority by setting the price of electricity—and procedurally invalid—because the PUC failed to comply with the Administrative Procedure Act’s rulemaking procedures in issuing the order.The Supreme Court of Texas reviewed the case and held that the PUC’s approval order is not a “competition rule[] adopted by the commission” subject to the judicial-review process for PUC rules. The court found that PURA envisions a separate process for ERCOT-adopted protocols, and the statutory requirement that the PUC approve those adopted protocols does not transform PUC approval orders into PUC rules eligible for direct review by a court of appeals. Therefore, the Third Court of Appeals lacked jurisdiction over this proceeding. The Supreme Court of Texas vacated the court of appeals’ judgment and dismissed the case for lack of jurisdiction. View "Public Utility Commission v. RWE Renewables Americas, LLC" on Justia Law

The case revolves around the actions of the Public Utility Commission of Texas (Commission) during Winter Storm Uri, when the Texas electric grid was on the brink of collapse. The Commission issued two orders that effectively raised the market price of electricity to the regulatory ceiling of $9,000/MWh to incentivize generators to add supply and large industrial users to reduce their demand. This led to some market participants going bankrupt and subsequent litigation.The court of appeals held that the Commission’s orders exceeded its authority under Chapter 39 of the Public Utility Regulatory Act (PURA) because the statute prohibits price-setting. The court of appeals did not address whether the Commission complied with the Administrative Procedure Act’s (APA) procedural rulemaking requirements.The Supreme Court of Texas disagreed with the court of appeals' decision. It held that the Commission’s orders did not exceed its authority under PURA. The court also found that the Commission substantially complied with the APA’s procedural rulemaking requirements, an issue the court of appeals did not address. The Supreme Court of Texas reversed the judgment of the court of appeals and rendered judgment affirming the orders. View "Public Utility Commission v. Luminant Energy Co. LLC" on Justia Law

The case revolves around Pureza “Didit” Martinez, who was terminated from her position at the Texas Tech University Health Sciences Center at the age of 72. She filed a lawsuit alleging age discrimination against the Health Sciences Center, the Texas Tech University System, and the Texas Tech University System’s Board of Regents. The Texas Tech University System and the Board of Regents argued that they were not Martinez's employer and thus retained sovereign immunity.Previously, the trial court denied the plea to the jurisdiction filed by the Texas Tech University System and the Board of Regents, and the court of appeals affirmed this decision. The defendants argued that Martinez failed to plead allegations that could make them liable for age discrimination under the Labor Code, essentially denying being Martinez’s employer.The Supreme Court of Texas disagreed with the lower courts' decisions. The court found that Martinez's petition did not allege facts demonstrating that the Texas Tech University System or the Board of Regents employed Martinez directly or that either one controlled access to and interfered with her employment. Therefore, the court concluded that Martinez failed to allege a waiver of sovereign immunity, and the plea to the jurisdiction of the Texas Tech University System and the Board of Regents should have been granted. However, the court remanded the case to the trial court to give Martinez an opportunity to replead, as her petition did not foreclose a valid claim against those defendants. View "Texas Tech University System v. Martinez" on Justia Law

Mark and Birgit Self owned a tract of rural land that adjoined a portion of Farm-to-Market Road 677 in Montague County, Texas. The Texas Department of Transportation (TxDOT) had a right-of-way easement that reached fifty feet from the centerline of the road in each direction, which burdened part of the Selfs’ property. As part of a highway maintenance project, TxDOT contracted with T.F.R. Enterprises, Inc. (TFR) to remove brush and trees from the right-of-way. TFR subcontracted with Lyellco Inc. to remove the trees. Following TxDOT’s instruction to TFR to “clear everything between the fences,” Lyellco workers cut all trees up to the Selfs’ fence line, including trees that were outside the State’s right-of-way easement. The Selfs sued TxDOT for negligence and inverse condemnation.The trial court denied TxDOT’s plea to the jurisdiction, asserting immunity from both causes of action. On appeal, the court of appeals affirmed in part and reversed in part. It held that there was a fact issue on whether the Texas Tort Claims Act waived immunity for the negligence cause of action, but reversed the trial court’s judgment on the cause of action for inverse condemnation, holding there was no evidence that TxDOT intentionally destroyed the Selfs’ property.The Supreme Court of Texas disagreed with the court of appeals. It held that the Selfs had not shown either that the subcontractor’s employees were in TxDOT’s paid service or that other TxDOT employees operated or used the motor-driven equipment that cut down the trees, as required to waive immunity under the Tort Claims Act. Therefore, the negligence cause of action was dismissed. However, regarding inverse condemnation, the court found that the Selfs had alleged and offered evidence that TxDOT intentionally directed the destruction of the trees as part of clearing the right-of-way for public use. Therefore, the cause of action for inverse condemnation was remanded to the trial court for further proceedings. View "TEXAS DEPARTMENT OF TRANSPORTATION v. SELF" on Justia Law

The case involves the City of Houston, which appealed a wrongful-death suit filed by the family of Dwayne Foreman, who was killed in a collision with a police cruiser. The police officers were responding to a suicide call at the time of the accident. The City argued that it was immune from the lawsuit because the officer was performing a discretionary duty in good faith and within the scope of his authority.The trial court denied the City's motion for summary judgment, and the City appealed. The court of appeals affirmed the trial court's decision, holding that a fact issue existed on the officer’s good faith, which precluded summary judgment.The Supreme Court of Texas disagreed with the lower courts. It held that, as a matter of law, the officer was performing a discretionary duty while acting within the scope of his authority in responding to the emergency call and was acting in good faith. The court reasoned that a reasonably prudent officer in the same or similar circumstances could have believed the actions were justified. Therefore, the court reversed the lower courts' decisions and dismissed the case. View "CITY OF HOUSTON v. SAULS" on Justia Law