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.
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.
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.
In re East Texas Medical Center Athens – 712 S.W.3d 88 – Apr 25, 2025
The Texas Supreme Court conditionally granted mandamus relief in favor of the Defendant-Employer, holding that the trial court abused its discretion by striking the employer’s designation of responsible third parties in a nonsubscriber negligence suit filed by the Plaintiff-Employee. The Court clarified that the proportionate responsibility statute applies to negligence claims against nonsubscribing employers because such suits are not “actions to collect workers’ compensation benefits” under the Workers’ Compensation Act. It also held that the Act does not prohibit nonsubscribers from designating responsible third parties, and that sufficient evidence supported the designation in this case. As the employer had no adequate remedy by appeal, the Court ordered the trial court to vacate its order striking the designation.
Accident Fund Insurance Company v Texas Department of Insurance, Division of Workers’ Compensation v. Mendiola – 707 S.W.3d 110 – Feb 7, 2025
The Supreme Court of Texas denied petitions for review in two cases involving entitlement to supplemental income benefits and provided explanations.
JNM Express, LLC v. Lozano – 688 S.W.3d 327 – Apr 19, 2024
The Texas Supreme Court remanded the case to the court of appeals to consider the merits of whether the trial court correctly used the federal regulations’ definitions of “employer” and “employee” in the jury charge, including whether the federal regulations’ definitions preempt the state-law analysis for determining employment status for purposes of the workers’-compensation system and state tort law.
HNMC, Inc. v. Chan – 683 S.W.3d 373 – Jan 19, 2024
The Texas Supreme Court reversed the lower court’s holding regarding the specialized, case-specific duty owed by the Employer-Defendant when the Employee-Plaintiff was killed on an adjoining public roadway. Although the workers compensation bar was raised, the Court did not discuss the arguments because it found no duty was owed.
In re Rudolph Automotive, LLC – 674 S.W.3d 289 – Jun 16, 2023
The Texas Supreme Court conditionally granted mandamus relief and directed the district court to vacate its new-trial order, harmonize the verdict, and proceed in the normal course with the post-trial stages of litigation.
Fortenberry v. Great Divide Insurance Company – 664 S.W.3d 807 – Mar 31, 2023
The Texas Supreme Court reversed the lower court’s order regarding venue where the Plaintiff-Employee was a football player that claimed to reside at a hotel in Dallas. The Court noted that the record adequately demonstrated that the Plaintiff-Employee “resided” in Dallas County at the time of his injury as Section 410.252(b) requires.