Texas Military Department v. Lopez – 13-25-00150-CV – Dec 18, 2025
The Corpus Christi–Edinburg Court of Appeals reversed the trial court’s denial of the Texas Military Department’s plea to the jurisdiction and rendered judgment dismissing the Lopezes’ tort suit for lack of jurisdiction, holding sovereign immunity was not waived under the Texas Tort Claims Act because the crash arose from “activities of the state military forces” while the servicemember was on state active duty under lawful orders. In reaching that result, the court relied heavily on workers’ compensation concepts, especially the personal comfort doctrine and distinct-departure analysis, to conclude that stopping briefly for restroom/food/refueling while on shift did not remove the servicemember from the “activity” of the mission.
In re ExxonMobil Corp – 14-25-00446-CV – Dec 18, 2025
The Fourteenth Court of Appeals (Houston) conditionally granted mandamus and ordered the trial court to vacate its order denying ExxonMobil’s summary judgment and instead grant summary judgment and dismiss all claims because the Texas Workers’ Compensation Act’s exclusive-remedy bar applied. ExxonMobil proved a written §406.123 agreement and that its OCIP program provided Texas workers’ comp coverage to the subcontractor’s employees, including the plaintiff. The court also held no choice-of-law analysis was needed because the asserted Texas/Louisiana differences were not outcome-determinative for this non-fatal injury case, and it rejected the plaintiff’s intentional-tort exception theory as legally insufficient (at most it showed an unsafe “eventual disaster,” not a substantially certain injury to this employee).
Hirsch v. City of Houston – 731 S.W.3d 50 – Dec 16, 2025
The Fourteenth Court of Appeals reversed the trial court’s order granting the City’s plea to the jurisdiction and remanded for further proceedings, holding Hirsch presented evidence raising a fact issue that a police academy cadet can qualify as a “first responder,” which would trigger the limited waiver of governmental immunity for a Texas Labor Code chapter 451 workers’ compensation retaliation claim. The court also concluded the TCHRA retaliation provision protects job applicants as well as current employees, so the City’s “not an employee anymore” immunity/standing theory did not defeat jurisdiction at this stage.
In re Dollar Stores, Inc. – 14-25-00668-CV – Dec 9, 2025
The court of appeals conditionally granted mandamus and ordered the trial court to vacate its discovery order requiring Family Dollar to produce broad incident-report data for all Texas stores (and nationwide shootings), holding those requests were overbroad and improper “fishing expeditions” under the Texas discovery rules. The court found that, even in a gross-negligence case, discovery must be reasonably tailored in time, place, and subject matter to the specific incident and claims at issue. Because the trial court compelled overly broad discovery, mandamus (not a post-judgment appeal) was the appropriate remedy.
City of Houston v. Gutierrez – 14-24-00811-CV – Dec 9, 2025
The court of appeals reversed the trial court and dismissed the plaintiffs’ claims after holding that the City of Houston retained governmental immunity because its firefighter was not in the course and scope of employment when the MVA occurred. The court applied the “coming-and-going” rule, concluding that the firefighter was merely commuting to work and not performing any City business. The court also rejected the plaintiffs’ reliance on workers’ compensation “dual-purpose” cases, explaining that those doctrines do not apply in the TTCA context and, even if they did, no work-related purpose existed.
Galvan v. Hyatt Regency San Antonio – 04-24-00829-CV – November 26, 2025
The court of appeals reversed the trial court’s order granting Hyatt’s plea to the jurisdiction and motion to dismiss and remanded the case for further proceedings. The court held that Galvan’s district court petition, though styled as a “breach of contract” claim, was in substance a timely petition for judicial review of a Texas workers’ compensation appeals panel decision under Labor Code § 410.252(a). Applying the statute’s deemed mailing rule, the court concluded Galvan sued only eight days after the presumed mailing date, well within the 45-day deadline. The opinion also notes that several grounds raised in Hyatt’s plea (exclusive remedy, service on DWC, and failure to plead panel determinations) are not jurisdictional and therefore do not support dismissal for lack of subject-matter jurisdiction.
Taylor v. Norton – 06-25-00014-CV – Nov 21, 2025
Although this case does not arise from the Texas Workers’ Compensation system, it is relevant because it interprets how statutory definitions, particularly “family” and “consanguinity,” continue to operate even after termination of parental rights. The court held that biological descent, not legal parental status, controls whether someone qualifies as “family” under statutes that incorporate Government Code §573.022. This principle applies similarly in workers’ compensation contexts, where standing, beneficiary status, and certain rights depend on statutory family relationships rather than custody or adoption history. Thus, the decision confirms that termination and adoption do not erase consanguinity for statutes that rely on blood relationship, a concept that can inform workers’ compensation analyses involving death benefits and related determinations.
Harris County v. Doe – 01-24-00096-CV
Although this case was pled as a TTCA premises-defect/intentional-injury suit, it arises from a workplace sexual assault at a county jail and directly implicates the Texas Workers’ Compensation Act’s exclusive-remedy rule. The court held that all claims against Harris County and its officials had to be dismissed because (1) the TTCA’s election-of-remedies provision required dismissal of claims against the individual officials, and (2) the pleadings did not allege a premises condition that could waive immunity—making the jail merely the location of a third-party assault. Importantly for workers’ compensation, the court rejected the employee’s attempt to bypass the TWCA by labeling the county’s alleged understaffing as “intentional,” confirming that the intentional-injury exception is extremely narrow and does not apply to negligent or systemic staffing decisions.
Lee v. Grand Prairie Independent School District – 03-25-00243-CV
This case arises directly from a workers’ compensation judicial-review suit, but the court did not reach any compensability or extent-of-injury issues. Instead, the appeal was dismissed for lack of jurisdiction because the claimant filed her notice of appeal more than 50 days after the extended deadline, and she did not qualify for a restricted appeal. The court held that a party who participated in the trial-court hearing and filed post-judgment motions cannot use restricted-appeal procedures to cure an untimely notice of appeal.
LKQ Automotive v. Romo – 08-25-00104-CV – Oct 31, 2025
The El Paso Court of Appeals affirmed the denial of LKQ and Duron’s motion to compel arbitration. The court held the employee qualified for the FAA § 1 transportation-worker exemption, so the FAA did not require arbitration. Because appellants did not seek enforcement under the TAA or other state law, the arbitration agreement was not enforced and the case returns to the trial court.