Texas Case Summaries
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Texas 13th Court of Appeals, Appellate Procedure, Civil Procedure, Municipal Law

City of Edinburg v. Texas Cordia Construction — City Cannot Block Contractor’s Immunity Evidence by Limiting Its Jurisdictional Challenge to Pleadings

The Thirteenth Court of Appeals held that a city cannot bar a contractor from presenting jurisdictional evidence by framing its plea to the jurisdiction as a pleadings-only challenge, and that amounts owed under a termination-for-convenience clause are “due and owed” within the Texas Local Government Code’s immunity waiver.

Texas 13th Court of Appeals, Constitutional, Criminal

Magnuson v. State — Trial Court Violated Defendant’s Faretta Right to Self-Representation at Deferred Adjudication Hearing

The Texas Thirteenth Court of Appeals reversed a ten-year deferred-adjudication conviction, holding the trial court violated Magnuson’s Faretta right to self-representation at the adjudication hearing when it denied his unequivocal request to proceed pro se—over the State’s delay-tactic objection—without making the required findings that the request was knowing, voluntary, and timely.

Texas 15th Court of Appeals, Constitutional, Criminal

Texas State Board of Social Worker Examiners v. Youniacutt — Automatic License Bar for Violent Felony Convictions Survives Constitutional Challenge

The Texas Fifteenth Court of Appeals reversed the trial court and dismissed challenges to Texas Occupations Code § 108.052(2)’s automatic denial of social worker licenses to applicants with prior violent felony convictions, holding that the categorical disqualification survives rational-basis review under Patel because protecting vulnerable patients is a legitimate government interest and the bar is not oppressively burdensome.

Texas 15th Court of Appeals, Insurance Coverage

Public Utility Commission v. City of Denton — Court Affirms Rate Decision Reversing Commission’s Mid-Proceeding RFP Change for Municipal Transmission Utility

The Texas Fifteenth Court of Appeals affirmed a district court ruling that the PUC’s mid-proceeding modification of its rate filing package without Texas Register publication was arbitrary and capricious, requiring application of the pre-amendment 0.25x debt service coverage adder presumption, while upholding the Commission’s exclusion of a municipal utility’s general fund transfer return-on-investment component as insufficiently substantiated.

Breach of Contract, Construction Law, Contract Interpretation

Blackmon Mooring v. St. Edward’s University — Third Court Reverses Summary Judgment, Holds Parol Evidence Cannot Transform Cost Estimate into Price Cap

The Third Court of Appeals reversed summary judgment for St. Edward's University, holding that the parol evidence rule prohibited using pre-contract negotiations to transform a cost-plus contract's 'estimated budgetary price' into a guaranteed maximum price.

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