Williams v. Richardson Independent School District
The Dallas Court of Appeals affirmed the trial court’s no-evidence summary judgment in favor of the self-insured school district. The case involved judicial review of a Division of Workers’ Compensation decision allowing the district to adjust the claimant’s average weekly wage due to nonduty days during school breaks. The court held that the claimant failed to raise a genuine issue of material fact about his reasonable expectation to earn wages on those disputed dates and did not meet procedural requirements to delay summary judgment for further discovery.
In re Gulf Coast Flooring and Services LLC – 01-25-00057-CV – Jul 3, 2025
The Houston First Court of Appeals denied the employer’s petition for writ of mandamus seeking to compel the probate court to dismiss claims based on alleged failure to exhaust administrative remedies through the Texas Department of Insurance, Division of Workers’ Compensation. The employer had argued that the Division had exclusive jurisdiction to determine whether the decedent was an employee or independent contractor. The court rejected the mandamus petition but allowed the employer to request reconsideration in probate court based on the Texas Supreme Court’s recent decision in Oteka.
Thornton v. City of Plano, Texas – 05-24-01330-CV
The 5th Court of Appeals (Dallas) affirmed the trial court’s dismissal of Erin Thornton’s claims against the City of Plano and Police Chief Ed Drain. Thornton, a police officer injured in the line of duty, alleged violations of Texas Local Government Code § 177A.003 and retaliation for filing a workers’ compensation claim. The court upheld the jurisdictional dismissal, finding that Thornton failed to challenge an independent ground raised by the City and Drain—that Chapter 177A does not apply to civil service municipalities like Plano, which are instead governed by Chapter 143. As a result, her claims under Chapter 177A and for mandamus relief were dismissed with prejudice.
Thomas v. Iron Horse Terminals, L.L.C. – 09-23-00203-CV – Jun 19, 2025
The 9th Court of Appeals (Beaumont) affirmed summary judgment in favor of Iron Horse Terminals, L.L.C. (IHT), holding that it was not a common carrier under the Federal Employers’ Liability Act (FELA). Because IHT was a Texas Workers’ Compensation subscriber and not a common carrier engaged in interstate commerce, the court found that Jermaine Thomas’s exclusive remedy for his work injury was through the state workers’ compensation system. The court concluded that Thomas’s FELA claim failed as a matter of law, and it did not need to address whether his acceptance of workers’ compensation benefits barred his FELA claim.
University of Texas Rio Grande Valley v. Oteka – 715 S.W.3d 734 – Jun 13, 2025
The Texas Supreme Court held that the Division of Workers’ Compensation does not have exclusive jurisdiction to determine whether an injury was work-related when that issue arises solely as an affirmative defense in a personal injury lawsuit and the employee is not seeking workers’ compensation benefits. The Court emphasized that a district court retains jurisdiction in such cases unless the employee’s claim hinges on entitlement to benefits. Because Oteka never filed a claim for benefits and the issue of compensability was not raised until years later, the Court affirmed the lower court’s decision denying the employer’s jurisdictional plea.
Energy Transfer, LP v. Moock – 4-23-00858-CV – Jun 3, 2025
The 14th Court of Appeals (Houston) reversed the trial court’s denial of a motion to compel arbitration and held that the plaintiff’s workplace personal injury claims, which arose from a pipeline explosion, must be submitted to arbitration under the Federal Arbitration Act. The case raised issues of course and scope of employment often addressed in workers’ compensation claims. The court determined that the plaintiff was not a transportation worker exempt from the FAA and that the arbitration agreement was valid and enforceable by the defendant companies.
Renaissance Medical Foundation v. Lugo – 719 S.W.3d 505 – May 23, 2025
The Texas Supreme Court clarified the scope of vicarious liability for nonprofit health organizations (NPHOs) that employ physicians. While the case arose from a medical malpractice claim, it has important implications for Texas workers’ compensation because the Court modified the traditional “right of control” test used to determine employment relationships—central to deciding employer liability in workers’ compensation cases. By holding that NPHOs cannot be vicariously liable where control would interfere with a physician’s independent medical judgment, the Court introduced a statutory exception to common-law employment principles, signaling a nuanced approach that could affect how similar relationships are evaluated under the Workers’ Compensation Act.
Jones v. Mansfield Independent School District – 02-24-00355-CV – May 15, 2025
The 2nd Court of Appeals (Ft. Worth) affirmed the dismissal of Joyce L. Jones’s lawsuit against Mansfield Independent School District, holding that the trial court properly granted a plea to the jurisdiction. Jones’s claims centered on alleged mishandling of her workers’ compensation case but did not seek judicial review of issues actually adjudicated by the Division of Workers’ Compensation. Because she failed to raise any legitimate appellate issues and did not exhaust administrative remedies for her claims, the court found it lacked jurisdiction.
Seward v. Santander – 713 S.W.3d 341 – May 9, 2025
Reversing the Dallas Court of Appeals, the Texas Supreme Court dismissed all negligence and vicarious-liability claims against off-duty officer Chad Seward, Home Depot, and Point2Point, holding that Seward acted within the governmental scope of his police duties and that the newly adopted public-safety-officer rule bars suits by responding officers for injuries caused by the very peril that summoned them. The ruling reinstates the trial court’s take-nothing judgment and leaves only the criminal shooter liable. Although no workers-compensation dispute was litigated, the decision confirms that first-responder injuries arising from emergency response are to be addressed through statutory benefits rather than tort damages against the premises owner, narrowing potential subrogation or third-party recovery avenues for workers-comp carriers.
Red Bluff LLC v. Tarpley – 713 S.W.3d 412 – May 9, 2025
Vacating the Fourteenth Court of Appeals’ affirmance, the Texas Supreme Court ruled that nonsubscriber employer Red Bluff, LLC timely preserved its post-judgment attacks because its lawyer lacked “actual knowledge” of the $7.1 million verdict when notice arrived only by email, not first-class mail. The Court therefore reversed the limitations ruling and remanded for the trial court to hear Red Bluff’s motions for new trial and JNOV.