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Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. 11-0265
Regular Panel Decision
Aug 30, 2013

the Episcopal Diocese of Fort Worth v. the Episcopal Church

This case addresses a property dispute between The Episcopal Diocese of Fort Worth and The Episcopal Church following a denominational schism. The Supreme Court of Texas reviewed the trial court's grant of summary judgment, which was based on the "deference" methodology for resolving church property disputes. Reaffirming its holding in Masterson v. Diocese of Northwest Texas, the Court mandated the application of "neutral principles of law" as the correct methodology for such cases in Texas. The Court found the trial court erred by applying the deference principles and determined that the record did not warrant rendition of judgment for either party under neutral principles. Consequently, the judgment was reversed, and the case remanded for further proceedings consistent with the neutral principles methodology, requiring consideration of deeds, church charters, and state statutes.

Religious Property DisputeChurch SchismNeutral Principles of LawDeference MethodologySummary JudgmentTexas Supreme CourtEcclesiastical LawProperty OwnershipFirst AmendmentNon-Profit Corporation Act
References
14
Case No. MISSING
Regular Panel Decision

In re the Lithuanian Workers' Literature Society

The Lithuanian Workers’ Literature Society appealed a Kings Special Term order denying its motion to amend its certificate of incorporation. The proposed amendment sought to broaden membership qualifications from adhering to the Socialist Party to not opposing "Marxian principles". The court scrutinized whether "Marxian principles" endorse the overthrow of government by force, which is criminal under state Penal Law. Citing Karl Marx's historical support for forceful revolutions (e.g., Paris Commune), the court concluded that these principles were broad enough to justify illegal propaganda. Furthermore, the court noted that the proposed amendment would allow retention of members advocating "direct action" by force, contrary to the Socialist Party's recently amended platform promoting constitutional methods. Consequently, the appellate court affirmed the denial of the amendment, refusing to sanction an organization whose principles could potentially endorse unlawful means.

Corporate AmendmentSocialismMarxian PrinciplesFreedom of AssociationPolitical PropagandaConstitutional LawPenal LawAppellate ReviewMembership Corporations LawDirect Action
References
6
Case No. MISSING
Regular Panel Decision

Episcopal Diocese of Fort Worth v. Episcopal Church

The case concerns a property dispute between The Episcopal Church (TEC) and the Episcopal Diocese of Fort Worth following the Diocese's attempted withdrawal from TEC. The primary issue revolves around which methodology—"deference" or "neutral principles of law"—Texas courts should apply to determine entitlement to religious organization property after a schism. The trial court initially applied the "deference" methodology, granting summary judgment to TEC. However, the appellate court, aligning with its precedent in *Masterson v. Diocese of Northwest Texas* (2013), ruled that the "neutral principles of law" methodology is the appropriate standard. Due to insufficient evidence in the record, particularly regarding property deeds and corporate actions, to fully apply neutral principles, the court reversed the trial court's judgment and remanded the case for further proceedings. The opinion also provides guidance to the trial court on issues concerning trust creation under Texas law and the scope of applying neutral principles.

Property disputeReligious organizationsChurch schismNeutral principles of lawDeference methodologyTexas Supreme CourtEpiscopal ChurchFort Worth DioceseChurch propertyConstitutional law
References
9
Case No. MISSING
Regular Panel Decision

Mansfield v. Colonial Freight Systems

Craig Mansfield died as a passenger in a vehicle driven by his intoxicated cousin, Brett Steele, which collided with a tractor trailer owned by Colonial Freight Systems. Mansfield's estate sued Colonial, alleging negligence for the truck driver's failure to place emergency reflectors. The trial court granted summary judgment to Colonial, finding the driver's conduct was not the proximate cause of the accident. On appeal, the court affirmed the summary judgment, concluding that Mansfield was contributorily negligent by knowingly riding with an intoxicated driver, thereby barring his claim against Colonial under traditional negligence principles. The court noted that comparative fault principles were not applicable as the issue was not raised at an appropriate stage.

Contributory Negligence DoctrineProximate Causation AnalysisSummary Judgment StandardsVehicle Collision LiabilityDriving Under Influence (DUI)Passenger NegligenceComparative Fault InapplicabilityAppellate Court AffirmationTortious ConductForeseeable Harm
References
26
Case No. W2019-02184-COA-R3-CV
Regular Panel Decision
Nov 25, 2020

Sypriss Smith v. All Nations Church of God

Former employee Sypriss Smith sued her former employer, All Nations Church of God, for retaliatory discharge, disability discrimination, and religious discrimination. A jury found in favor of Smith only on the retaliatory discharge claim under the Tennessee Public Protection Act (TPPA), awarding $15,500.00. Smith sought over $100,000.00 in attorney's fees, which the trial court reduced to $12,500.00, proportional to the punitive damages. Smith appealed the attorney's fee award, arguing the trial court abused its discretion by not fully considering all factors under Tenn. Sup. Ct. R. 8, RPC 1.5(a), and by overly focusing on proportionality. The Court of Appeals vacated the trial court's judgment and remanded the case for a more detailed explanation of its attorney's fee determination.

Retaliatory DischargeAttorney FeesAbuse of DiscretionTennessee Public Protection ActTPPADamagesPunitive DamagesAppellate ReviewJudicial DiscretionRule 1.5(a)
References
36
Case No. 03-06-00529-CV
Regular Panel Decision
Feb 13, 2009

Helen O'Neal v. Ector County Independent School District and the Commissioner of Education

This dissenting opinion concerns a motion for reconsideration en banc regarding a case involving American Protection Insurance Company and Liana Leordeanu. The dissent argues that the majority opinion deviates from the "continuous coverage principle," which states that an employee whose work involves travel remains within the course of employment continuously during a trip. Justice Henson highlights that Leordeanu was a traveling salesperson without a fixed place of employment, making the continuous coverage principle applicable. Citing established precedents like Aetna Cas. & Sur. Co. v. Orgon and Texas Employers Ins. Ass’n v. Cobb, the dissent contends that injury during an overnight stay on a business trip is compensable. Therefore, the dissenting justice adopts Justice Patterson's reasoning and respectfully dissents from the denial of en banc consideration.

Continuous Coverage PrincipleTraveling SalespersonWorkers' Compensation ActCourse of EmploymentEn Banc ReviewDissenting OpinionInsurance LawAppellate CourtTexas LawWork-Related Injury
References
5
Case No. MISSING
Regular Panel Decision

Masterson v. Diocese of Northwest Texas

This Texas Supreme Court opinion addresses a church property dispute involving The Episcopal Church of the Good Shepherd. A majority of the local congregation voted to withdraw from The Episcopal Church of the United States (TEC) and the Episcopal Diocese of Northwest Texas due to doctrinal differences, renaming itself the Anglican Church of the Good Shepherd. The Diocese and loyal faction (Episcopal Leaders) sued to gain control of the property. The Court held that Texas courts must apply 'neutral principles of law' to resolve church property disputes, rather than deferring to hierarchical church decisions on property ownership. The previous summary judgment in favor of the Episcopal Leaders, based on the deference methodology, was reversed. The case was remanded for further proceedings consistent with the neutral principles approach, focusing on corporate bylaws, deeds, and state law regarding property and trusts.

Church Property DisputeNeutral Principles of LawDeference MethodologyFirst AmendmentFreedom of ReligionHierarchical ChurchTexas Supreme CourtCorporate GovernanceNon-Profit CorporationsTrust Law
References
59
Case No. MISSING
Regular Panel Decision

Findley v. Falise

This 'AMENDED MEMORANDUM, ORDER, AND JUDGMENT' addresses an unresolved issue from a class action settlement against the Manville Trust, concerning the allocation of payment responsibility under Maryland law. Following a remand from the Second Circuit Court of Appeals, the New York district and bankruptcy courts were mandated to predict how the Maryland Court of Appeals would apply set-off principles to this unique settlement. The courts considered arguments from various parties, including proposals for treating the Manville Trust, which is solvent but unable to fully meet its liabilities. Ultimately, the decision was to interpret Maryland law as excluding the Manville Trust from pro rata share calculations for other settling defendants, while crediting amounts settled by the Trust to non-settling joint tortfeasors. This ruling, detailed in Part V.A of the Order, aims to equitably balance the interests of all parties while adhering to Maryland law principles given the distinct circumstances of the Trust.

Asbestos LitigationClass Action SettlementManville TrustMaryland LawSet-off PrinciplesJoint TortfeasorsFederal Court JurisdictionAbstention DoctrineDeclaratory JudgmentTort Law
References
23
Case No. MISSING
Regular Panel Decision

City of New York v. United States

This case involves a facial constitutional challenge brought by New York City against two federal statutory provisions: Section 434 of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 and Section 642 of the Illegal Immigration Reform and Immigrant Responsibility Act of 1996. These federal laws preempt a New York City ordinance that restricts City officials from sharing information about aliens' immigration status with federal authorities. The plaintiffs argued that the federal provisions violated the Tenth Amendment, the Guarantee Clause, and principles of federalism by commandeering the City's policymaking apparatus and interfering with core governmental functions. The court, presided over by District Judge Koeltl, granted the defendants' motion for judgment on the pleadings and dismissed the action, holding that the federal statutes merely prevented local interference with voluntary information exchange and did not unconstitutionally compel state action or violate the principles invoked by the plaintiffs.

FederalismTenth AmendmentGuarantee ClausePreemptionImmigration StatusState SovereigntyLocal GovernmentInformation SharingConstitutional LawStatutory Challenge
References
27
Case No. 11-0332
Regular Panel Decision
Aug 30, 2013

Robert Masterson, Mark Brown, George Butler, Charles Westbrook, Richey Oliver, Craig Porter, Sharon Weber, June Smith, Rita Baker, Stephanie Peddy, Billie Ruth Hodges, Dallas Christian, and the Episcopal Church of the Good Shepherd v. the Diocese of Northwest Texas, the Rev. Celia Ellery, Don Griffis, and Michael Ryan

This case concerns a property dispute arising from a schism within a local church, The Episcopal Church of the Good Shepherd, after a majority of its members voted to disassociate from The Episcopal Church (TEC). The Diocese of Northwest Texas and loyal parishioners sued for control of the property, which was held by the church as a non-profit corporation. The Texas Supreme Court addressed the legal methodology for resolving such church property disputes, ultimately holding that Texas courts must apply the "neutral principles of law" approach, rather than the "deference" approach. This methodology requires civil courts to decide non-ecclesiastical issues like property ownership based on generally applicable secular law. Consequently, the Court reversed the lower court's summary judgment, which had been granted using the deference methodology, and remanded the case for further proceedings consistent with the neutral principles approach, emphasizing that the secular legal aspects of corporate governance and property ownership must be examined.

Church Property DisputeReligious AutonomyNeutral Principles of LawHierarchical ChurchCorporate GovernanceChurch SchismFirst AmendmentFree Exercise ClauseSummary JudgmentTexas Supreme Court
References
60
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