Texas Case Commentaries

Establishing the Boundaries of Derivative Appeals and Fiduciary Duties in Partnership Disputes: The Bertucci-Watkins Precedent

Date: Mar 15, 2025

Establishing the Boundaries of Derivative Appeals and Fiduciary Duties in Partnership Disputes: The Bertucci-Watkins Precedent I. Introduction The case of Christopher F. Bertucci, acting as executor...

Texas Narrows Interlocutory Venue Appeals: Section 15.003(b) Applies Only When a Plaintiff’s Independent Venue Showing Is Actually at Issue

Date: Mar 14, 2025

Texas Narrows Interlocutory Venue Appeals: Section 15.003(b) Applies Only When a Plaintiff’s Independent Venue Showing Is Actually at Issue I. Introduction Rush Truck Centers of Texas, L.P. AND BLUE...

Redundant-Remedies Doctrine Turns on Remedies, Not Claims: Ultra Vires and As-Applied Constitutional Suits May Proceed Beyond APA Order-Reversal

Date: Mar 14, 2025

Redundant-Remedies Doctrine Turns on Remedies, Not Claims: Ultra Vires and As-Applied Constitutional Suits May Proceed Beyond APA Order-Reversal Case: REYNALDO "REY" GONZALEZ, JR., M.D., J.D. v....

Minor Briefing Defects Do Not Forfeit Derivative Appeals; Rule 38.9(b) Is the Proper Remedy

Date: Mar 13, 2025

Minor Briefing Defects Do Not Forfeit Derivative Appeals; Rule 38.9(b) Is the Proper Remedy Supreme Court of Texas — CHRISTOPHER F. BERTUCCI, AS OF THE ESTATE OF ANTHONY R. BERTUCCI, AND DERIVATIVELY...

Foreclosure Judgment Validating a Lien Does Not Bar a Later JOA Cost-Sharing Breach Claim When the Foreclosure Court Did Not Necessarily Decide It (and the Lienholder Previously Urged No Jurisdiction)

Date: Mar 13, 2025

Foreclosure Judgment Validating a Lien Does Not Bar a Later JOA Cost-Sharing Breach Claim When the Foreclosure Court Did Not Necessarily Decide It (and the Lienholder Previously Urged No...

Passive-Voice Habendum Clauses Do Not Imply a “Produced by the Lessee” Requirement

Date: Mar 13, 2025

Passive-Voice Habendum Clauses Do Not Imply a “Produced by the Lessee” Requirement I. Introduction In DAVID W. CROMWELL v. ANADARKO E&P ONSHORE, LLC, the Supreme Court of Texas addressed a recurring...

Default Rule: Oil-and-Gas Conveyance Includes Control of Incidentally Produced Groundwater in Liquid-Waste Byproduct Unless Expressly Reserved

Date: Mar 13, 2025

Default Rule: Oil-and-Gas Conveyance Includes Control of Incidentally Produced Groundwater in Liquid-Waste Byproduct Unless Expressly Reserved 1. Introduction Cactus Water Services, LLC v. COG...

Death-Penalty Discovery Sanctions Require Proof of Possession/Control and Flagrant Bad Faith, Plus Consideration of Lesser Sanctions

Date: Mar 12, 2025

Death-Penalty Discovery Sanctions Require Proof of Possession/Control and Flagrant Bad Faith, Plus Consideration of Lesser Sanctions I. Introduction In re Newkirk Logistics, Inc. is a Texas Supreme...

Texas Appellate Briefing Waiver: Courts Must Avoid Overly Technical Forfeitures and Reach Derivative-Claim Merits When Briefing Fairly Presents the Issues

Date: Mar 12, 2025

Texas Appellate Briefing Waiver: Courts Must Avoid Overly Technical Forfeitures and Reach Derivative-Claim Merits When Briefing Fairly Presents the Issues 1) Introduction Case: CHRISTOPHER F....

Foreclosure Judgments Do Not Bar Later Contract Claims Not Necessarily Decided—Especially When the Foreclosing Party Previously Defeated Jurisdiction Over the Contract Dispute

Date: Mar 11, 2025

Foreclosure Judgments Do Not Bar Later Contract Claims Not Necessarily Decided—Especially When the Foreclosing Party Previously Defeated Jurisdiction Over the Contract Dispute Court: Supreme Court of...

DTPA Civil Investigative Demands Must Be Statutorily Clear, Discovery-Limited, and Cannot Compel Third-Party Sworn Statements or Associationally Protected Member Identities

Date: Mar 11, 2025

DTPA Civil Investigative Demands Must Be Statutorily Clear, Discovery-Limited, and Cannot Compel Third-Party Sworn Statements or Associationally Protected Member Identities Decision commented on:...

Section 15.003(b) Interlocutory Venue Appeals Require an Actual “Independent Venue” Determination, Not Merely Multiple Plaintiffs

Date: Mar 11, 2025

Section 15.003(b) Interlocutory Venue Appeals Require an Actual “Independent Venue” Determination, Not Merely Multiple Plaintiffs I. Introduction Case: Rush Truck Centers of Texas, L.P. and Blue Bird...

Texas DTPA Investigative Demands Must State a Clear Statutory Basis and Subject Matter, Seek Only Discoverable Information, and Limit Sworn-Statement Demands to DTPA Targets

Date: Mar 11, 2025

Texas DTPA Investigative Demands Must State a Clear Statutory Basis and Subject Matter, Seek Only Discoverable Information, and Limit Sworn-Statement Demands to DTPA Targets I. Introduction This...

Default Rule: Oil-and-Gas Leases Convey Control of Incidentally Produced Groundwater (Produced Water) Absent Express Reservation

Date: Mar 11, 2025

Default Rule: Oil-and-Gas Leases Convey Control of Incidentally Produced Groundwater (Produced Water) Absent Express Reservation 1. Introduction Case: Cactus Water Services, LLC v. COG Operating,...

Religious Conference May Sue to Enforce Control Rights Under BOC § 22.207 and Assert Third-Party-Beneficiary Contract Claim Based on Nonprofit Articles

Date: Mar 11, 2025

Religious Conference May Sue to Enforce Control Rights Under BOC § 22.207 and Assert Third-Party-Beneficiary Contract Claim Based on Nonprofit Articles I. Introduction In SOUTHERN METHODIST...

DFPS’s Unequivocal Trial Withdrawal of Termination Bars a Termination Judgment Absent Clear Repudiation

Date: Mar 11, 2025

DFPS’s Unequivocal Trial Withdrawal of Termination Bars a Termination Judgment Absent Clear Repudiation I. Introduction In D.V. v. Texas Department of Family and Protective Services, the Supreme...

Redundant-Remedies Doctrine Does Not Bar Ultra Vires and As-Applied Constitutional Claims Seeking Prospective Relief Beyond APA Reversal

Date: Mar 11, 2025

Redundant-Remedies Doctrine Does Not Bar Ultra Vires and As-Applied Constitutional Claims Seeking Prospective Relief Beyond APA Reversal I. Introduction Case: Reynaldo "Rey" Gonzalez, Jr., M.D., J.D....

Filing “With the Court” Under Property Code § 21.018(a) Means Filing With the Clerk (Including E‑Filing): Objection Period in Texas Condemnation Cases Starts Upon Clerk Filing

Date: Feb 22, 2025

Filing “With the Court” Under Property Code § 21.018(a) Means Filing With the Clerk (Including E‑Filing): Objection Period in Texas Condemnation Cases Starts Upon Clerk Filing Introduction This per...

Pitts v. Rivas: Texas Supreme Court Formally Adopts the Anti‑Fracturing Rule and Clarifies Limits on Informal Fiduciary Duties in Professional Malpractice

Date: Feb 22, 2025

Formal Adoption of the Anti‑Fracturing Rule and Contract‑Driven Limits on Informal Fiduciary Duties: Pitts v. Rivas Introduction In Pitts, et al. v. Rivas, et al., the Supreme Court of Texas...

Defining "Operational" in BACT: A Texas Judicial Clarification

Date: Feb 20, 2025

Defining "Operational" in BACT: A Texas Judicial Clarification Introduction In the case of Port Arthur Community Action Network v. Texas Commission on Environmental Quality; Jon Niermann, in his...