Albertson's, Inc. v. Ortiz
Albertson's Inc. appealed a jury verdict awarding damages to Rachel Ortiz and John Downes, volunteer supporters of the United Farm Workers (UFW), who were arrested for leafleting at an Albertson's store in Austin. Ortiz and Downes sued Albertson's for the denial of their individual rights under the Texas Constitution. The central issue was whether the Texas Constitution's bill of rights is self-executing, creating a cause of action for damages against a private entity for infringing free-speech rights. The appellate court concluded that the Texas Constitution does not create such a tort action against private entities, distinguishing it from federal statutes like 42 U.S.C. § 1983 which applies to state actors. Consequently, the court reversed the trial court's judgment and rendered a judgment that Ortiz and Downes take nothing.