Justia Labor & Employment Law Opinion SummariesArticles Posted in Supreme Court of Texas
JLB Builders, LLC v. Hernandez
The Supreme Court reversed the judgment of the court of appeals holding that a fact issue existed as to whether a general contractor on a construction project owed a duty of care to its independent contractor's employee who was injured on the job, holding that no genuine issue of material fact existed regarding the existence of a duty.The trial court entered judgment in favor of the general contractor, concluding that there was no evidence to support the negligence elements of duty, breach, and causation. The court of appeals reversed as to the negligence claim, concluding that a fact issue existed regarding whether the contractor exercised actual control and thus owed the employee a duty, whether the contractor breached that duty, and whether the contractor's breach proximately caused the employee's injuries. The Supreme Court reversed, holding that the contractor owed the employee no duty as a matter of law. View "JLB Builders, LLC v. Hernandez" on Justia Law
Waste Management of Texas, Inc. v. Stevenson
The Supreme Court reversed the decision of the court of appeals reversing the judgment of the trial court granting summary judgment for Defendant in this workers' compensation case, holding that Plaintiff qualified as Defendants' employee under the Workers' Compensation Act, and therefore, the Act's exclusive remedy provision barred Plaintiff's claims.Plaintiff was an employee of a temporary staffing agency when he was injured while on assignment to a client of the agency. The staffing agency provided workers' compensation benefits. Plaintiff then sued Defendant, the client for whom he performed the work, alleging common-law negligence. The trial court granted summary judgment in favor of Defendant. The court of appeals reversed. The Supreme Court reversed, holding that summary judgment for Defendant was appropriate. View "Waste Management of Texas, Inc. v. Stevenson" on Justia Law
In re Copart, Inc.
The Supreme Court conditionally granted mandamus relief in this arbitration dispute, holding that the trial court abused its discretion in determining that pre-arbitration discovery was warranted in this case.After Plaintiff's employment was terminated she sued Defendant, her former employer, claiming discrimination and retaliation. Defendant moved to compel arbitration pursuant to the company's employee handbook acknowledgment and agreement, which contained an arbitration agreement. At issue was Plaintiff's second motion to compel pre-arbitration discovery claiming that an enforceable arbitration agreement did not exist. After the trial court granted the motion Defendant sought mandamus relief. The court of appeals denied the motion. The Supreme Court conditionally granted mandamus relief, holding that the trial court clearly abused its discretion in ordering pre-arbitration discovery because Plaintiff failed to provide the trial court with a reasonable basis to conclude that it lacked sufficient information to determine whether her claims were arbitrable. View "In re Copart, Inc." on Justia Law
Patients Medical Center v. Facility Insurance Corp.
The Supreme Court reversed the judgment of the court of appeals remanding this medical fee dispute between a health care provider and a worker's compensation insurance carrier over the proper amount of reimbursement for services rendered to a covered patient, holding that that administrative law judge (ALJ) who heard the case properly applied the rules of the Texas Department of Insurance, Division of Workers' Compensation in allocating the burden of proof.The provider initiated a dispute resolution proceeding, and the Division determined that the provider was entitled to more than the carrier believed was due. The Division ordered the carrier to pay the additional amount. The State Office of Administrative Hearings (SOAH) upheld the Division's determination. The court of appeals reversed, holding that the ALJ erred in placing the burden of proof on the carrier at the SOAH hearing and that the error prejudiced the carrier's substantial rights. The Supreme Court reversed, holding that the ALJ properly applied the Division's rules in concluding that the carrier had failed to meet its burden of proof. View "Patients Medical Center v. Facility Insurance Corp." on Justia Law
Texas Tech University Health Sciences Center-El Paso v. Flores
The Supreme Court reversed the judgment of the court of appeals affirming the judgment of the trial court denying the plea to the jurisdiction filed by Defendant, a governmental employer, and dismissed Plaintiff's age-discrimination claim for lack of jurisdiction, holding that the Texas Commission on Human Rights Act did not waive Defendant's sovereign immunity from this suit.Plaintiff sued for age discrimination. Defendant filed a plea to the jurisdiction. The trial court denied the plea, and the court of appeals affirmed. The Supreme Court reversed, holding (1) Plaintiff failed to submit legally sufficient evidence to establish a prima facie case of discrimination; and (2) because the legislature has not waived governmental immunity in the absence of such evidence, Plaintiff's age-discrimination claim must be dismissed for lack of jurisdiction. View "Texas Tech University Health Sciences Center-El Paso v. Flores" on Justia Law
Berkel & Co. Contractors, Inc. v. Lee
The Supreme Court affirmed the court of appeals' judgment notwithstanding the verdict but reversed its remand in the interest of justice, holding that the court of appeals correctly concluded that the evidence did not show that Employer believed that its actions were substantially certain to injure Plaintiff and that remand was not appropriate.Plaintiff was injured in a workplace accident. Plaintiff received workers' compensation medical and disability benefits for his injuries. Plaintiff then sued Employer for negligence and gross negligence, arguing that the common-law exception to the rule that the Texas Workers' Compensation Act is the exclusive remedy for employees who sustain nonfatal work-related injuries requiring that the defendant have a specific intent to injure the plaintiff applied. The jury entered a verdict in favor of Plaintiff, and the trial court entered judgment on the jury's verdict. The court of appeals reversed and rendered judgment for Employer. The Supreme Court affirmed the court of appeals' judgment notwithstanding the verdict and reversed its remand in the interest of justice, holding that the evidence confirmed that the accident fell short of a "genuine intentional injury." View "Berkel & Co. Contractors, Inc. v. Lee" on Justia Law
Texas Mutual Insurance Co. v. PHI Air Medical, LLC
In this dispute over the amount that air ambulance providers may recover from workers' compensation insurers, the Supreme Court held that Texas law requiring that private insurance companies reimburse the fair and reasonable medical expenses of injured workers is not preempted by a federal law deregulating aviation and that federal law does not require Texas to mandate reimbursement of more than a fair and reasonable amount for air ambulance services.PHI Air Medical, LLC, an air ambulance provider, argued that the federal Airline Deregulation Act (ADA) preempted the Texas Workers' Compensation Act's (TWCA) fee schedules and reimbursement standards. An administrative law judge held that PHI was entitled to reimbursement under the TWCA's standards. On judicial review, the trial court declared that the ADA did not preempt the TWCA's reimbursement provisions. The court of appeals reversed. The Supreme Court reversed, holding (1) because the price of PHI's service to injured workers is not significantly affected by a reasonableness standard for third-party reimbursement of those services, the ADA does not preempt that standard; and (2) the ADA does not require that Texas compel private insurers to reimburse the full charges billed for those services. View "Texas Mutual Insurance Co. v. PHI Air Medical, LLC" on Justia Law
Waak v. Rodriguez
The Supreme Court affirmed the judgment of the court of appeals holding that the Texas Farm Animal Activity Act (the Act), Tex. Civ. Proc. & Rem. Code 87.001-87.005, does not apply to ranchers and ranch hands, holding that the court of appeals did not err.The Act limits liability for injury to "a participant in a farm animal activity or livestock show" that results from an "inherent risk" of those activities. Raul Zuniga worked full-time for Conway and Marlene Waak to work cattle on a ranch, landscape, and cut hay. Zuniga died after being trampled. Plaintiffs, Zuniga's family, sued the Waaks, on wrongful death and survival claims. The trial court granted summary judgment for the Waaks, concluding that the Act barred Plaintiffs' claims. The court of appeals reversed, concluding that Zuniga was not "a participant in a farm animal activity" for whose injuries and death the Act limits liability. The Supreme Court affirmed, holding that the Act does not cover ranchers and ranch hands and, therefore, did not shield the Waaks from liability for their negligence resulting in Zuniga's death. View "Waak v. Rodriguez" on Justia Law
Mo-Vac Service Co., Inc.
The Supreme Court reversed the judgment of the court of appeals on Plaintiff's survival action and rendered judgment for Defendant, holding that Plaintiff's claims were barred by the exclusive-remedy provision of the Texas Workers' Compensation Act because her evidence did not raise a fact issue under the intentional-injury exception to the Act's exclusive remedy.Plaintiff's husband, an employee of Defendant, a trucking and warehousing company, died when his rig ran off the highway and rolled over. Plaintiff filed suit, arguing that her husband fell asleep at the wheel due to the fatigue of being overworked. At issue was whether there was any evidence that Defendant believed the accident was substantially certain to result from Plaintiff's being overworked. The trial court granted summary judgment for Defendant. The court of appeals reversed. The Supreme Court reversed, holding that Plaintiff failed to raise a fact issue on the applicability of the intentional-injury exception to the exclusive-remedy provision of the Act. View "Mo-Vac Service Co., Inc." on Justia Law
Office of Attorney General of Texas v. Rodriguez
The Supreme Court reversed the decision of the court of appeals affirming the judgment of the trial court concluding that a state agency violated the Texas Whistleblower Act, Tex. Gov't Code 554.002, when it fired one of its employees, holding that, under City of Fort Worth v. Zimlich, 29 S.W.3d 62 (Tex. 2000), no evidence demonstrated that the employee's report of a violation of state law more than one year earlier caused the agency to terminate the employee's employment.Laura Rodriguez, a regional manager for child-support services with the Office of the Attorney General, was fired fifteen months after reporting a violation of state law. Rodriguez sued the agency, claiming that it violated the Act because it fired her in retaliation for her protected activity. The trial court concluded that Rodriguez had made a good-faith report of a violation of law that caused the agency to terminate her employment. The court of appeals affirmed. The Supreme Court reversed, holding that the record evidence demonstrated that Rodriguez was fired based on conduct unrelated to her protected activity and that no evidence established that activity was a but-for cause of her termination. View "Office of Attorney General of Texas v. Rodriguez" on Justia Law