Rodriguez v. Christmas Tree Company, LLC – 07-25-00378-CV
The court of appeals affirmed summary judgment in favor of the employer, holding that the employee’s negligence claims were barred by the exclusive remedy provision of the Texas Workers’ Compensation Act. The court found undisputed evidence that Rodriguez was an employee acting within the course and scope of employment, that the employer maintained valid workers’ compensation coverage, and that Texas Mutual accepted the claim as compensable and paid benefits toward his medical expenses. The court also rejected Rodriguez’s arguments concerning the visiting judge’s authority and the exclusion of his affidavit, concluding those issues did not create a fact question defeating summary judgment. The opinion further clarified that the employer relied on the statutory exclusive-remedy defense, not the separate common law election-of-remedies doctrine.
Texas Association of Counties Risk Management Pool v. Adams – 09-25-00158-CV – May 8, 2026
The Beaumont Court of Appeals reversed the trial court’s denial of TACRMP’s plea to the jurisdiction and rendered judgment dismissing Dianna Adams’s claims for want of jurisdiction. The court held that TACRMP, as a governmental risk pool, was entitled to governmental immunity and was not the “insurance carrier” against whom the workers’ compensation death-benefits claim could proceed; instead, San Jacinto County was the self-insured carrier for Labor Code purposes. The court also held that the UDJA did not waive immunity because Adams sought declarations about how statutes applied to her claim rather than challenging the validity of those statutes, so the trial court lacked jurisdiction over both the workers’ compensation and declaratory claims.
R&L Carriers Shared Services LLC v. Gonzalez – 14-24-00992-CV – Apr 30, 2026
The court of appeals reversed the trial court and held that the employer and co-worker were entitled to compel arbitration of the wrongful-death claims arising from a workplace accident under a valid nonsubscriber arbitration agreement. The court determined the agreement was enforceable against the decedent’s beneficiaries because their claims were derivative and within the agreement’s scope, and the co-worker could enforce it as a third-party beneficiary. It also held that the plaintiffs waived any mediation condition precedent by filing suit without first seeking mediation. The case was remanded with instructions to compel arbitration and stay the litigation.
Hill v. Brazoria County – 14-24-00894-CV – Apr 28, 2026
The court of appeals affirmed summary judgment denying workers’ compensation death benefits, holding there was no reliable evidence that the decedent’s COVID-19 infection constituted a compensable occupational disease. The court upheld the exclusion of the claimant’s expert, finding his opinions unreliable and based on unsupported assumptions about workplace exposure. Without that expert testimony, the claimants failed to raise a fact issue that the decedent’s job exposed him to a greater risk of contracting COVID-19 than the general public. As a result, the denial of death benefits was affirmed.
In re Citgo Petroleum Corporation – 14-26-00106-CV – Apr 21, 2026
The court did not reach the merits of the workers’ compensation issue because the mandamus proceeding became moot after the parties settled the underlying dispute. The employer had challenged the denial of summary judgment based on the exclusive-remedy defense under the Texas Workers’ Compensation Act. However, due to settlement, the court dismissed the petition for writ of mandamus and lifted any stay, leaving no substantive ruling on the defense.
Argyle v. Miller – 05-25-00559-CV – Apr 16, 2026
This case isn’t a workers’ compensation benefits dispute in the usual sense, but it still brushes up against that world because it involves a nonsubscriber workplace injury plan replacing traditional comp coverage. The court of appeals reversed the trial court and held that the dispute had to go to arbitration under the employee’s signed agreement. The court found the arbitration agreement clearly delegated questions about its scope and conditions to the arbitrator, so the trial court overstepped by deciding those issues itself. The case was remanded with instructions to compel arbitration and stay the lawsuit.
Pineda v. National Specialty Insurance Company – 01-24-00383-CV – Apr 9, 2026
The court of appeals reversed the trial court’s dismissal for lack of jurisdiction, holding that although the claimant’s pleadings were deficient, they did not affirmatively negate jurisdiction under the Texas Workers’ Compensation Act. The record showed the claimant had in fact exhausted administrative remedies and was aggrieved by final Appeals Panel decisions, satisfying jurisdictional prerequisites. Because the defects in the pleadings were curable, the claimant was entitled to an opportunity to amend rather than dismissal. The case was remanded to allow amendment and further proceedings.
Kraemer v. City of Frisco Texas – 12-25-00273-CV – Apr 8, 2026
The court of appeals affirmed the trial court’s dismissal of the employee’s claims, holding that governmental immunity barred recovery and was not waived. The court determined that the City’s personnel policies did not create an enforceable contract due to an express disclaimer, defeating the breach of contract claim. It further held that the employee failed to establish prima facie claims for disability discrimination, failure to accommodate, or retaliation under the Texas Commission on Human Rights Act, so no statutory waiver of immunity applied. Accordingly, all claims were dismissed for lack of subject-matter jurisdiction.
Norman v. Kahn Scheepvaart BV – 14-24-00176-CV – Mar 31, 2026
The court of appeals affirmed a take-nothing judgment against the injured longshore worker, holding that most of her jury-charge complaints were not preserved for review and that the remaining alleged errors were either not erroneous or harmless. The court also found no reversible error in submitting a single broad-form negligence question rather than separate liability questions. Additionally, the claimant failed to support allegations of juror or bailiff misconduct with evidence, so the trial court properly denied a new trial.
Motiva Enterprises LLC v. Whitmire – 09-25-00053-CV – Mar 3, 2026
The court found Motiva Enterprises, LLC was entitled to summary judgment based on the exclusive-remedy provision of the Texas Workers’ Compensation Act. The court held that Motiva conclusively established it was the worker’s statutory employer because it provided workers’ compensation coverage through a valid agreement, and the worker had received benefits under that coverage. The appellate court rejected arguments that fact issues existed regarding the contract’s timing or that Motiva waived its defense by labeling the contractor as an independent contractor.