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

Case No. MISSING
Regular Panel Decision

Centerpoint Energy Entex v. Railroad Commission

This opinion addresses an appeal brought by CenterPoint Energy Entex concerning the Texas Railroad Commission's authority to conduct retroactive prudence reviews of gas charges passed through a purchased gas adjustment (PGA) clause and to order refunds. Entex also challenged whether such a review constitutes a 'ratemaking proceeding,' which would entitle the City of Tyler to expense reimbursement. The court affirmed the Commission's authority to conduct retroactive prudence reviews and order refunds, concluding it does not violate the filed rate doctrine or the rule against retroactive ratemaking. However, the court reversed the district court's decision regarding expense reimbursement, ruling that a prudence review is not a 'ratemaking proceeding' for the purpose of municipal expense recovery.

Utility RegulationGas UtilityPurchased Gas Adjustment ClausePGA ClauseRetroactive Prudence ReviewRatemaking ProceedingExpense ReimbursementTexas Railroad CommissionFiled Rate DoctrineRetroactive Ratemaking
References
69
Case No. MISSING
Regular Panel Decision

Cleary v. Board of Education

The petitioner, a substitute school teacher, sought retroactive membership in the New York State Teachers’ Retirement System after the enactment of Retirement and Social Security Law § 803. Respondent, her employer, denied her application. Petitioner then initiated a CPLR article 78 proceeding, which the Supreme Court granted, annulling the Hearing Officer's determination due to lack of a rational basis. The respondent appealed this decision. The Appellate Court affirmed the Supreme Court's judgment, concluding that the Hearing Officer's finding that the petitioner participated in a procedure requiring a formal decision to join the retirement system lacked a rational basis, as the evidence presented by the respondent, including W-4 forms, personnel notations, and general office practice testimony, was insufficient to meet the burden.

Retroactive membershipTeachers’ Retirement SystemCPLR article 78Rational basis reviewStandard office practiceEvidence sufficiencyConstitutional challengeSubstitute teacherPublic retirement systemNew York law
References
6
Case No. MISSING
Regular Panel Decision

Sibley, Lindsay & Curr Co. v. Bakery, Confectionery & Tobacco Workers International Union

Sibley, Lindsay and Curr Co. challenged the constitutionality of the Multiemployer Pension Plan Amendment Act of 1980 (MPPAA)'s retroactive withdrawal liability provisions. Sibley's had closed its bakery and withdrawn from a multiemployer pension fund on May 31, 1980, before the MPPAA was enacted on September 26, 1980, which made its withdrawal liability provisions retroactive to April 29, 1980, subjecting Sibley's to a $315,927.00 liability. The court applied the Nachman four-factor test to assess the due process implications of this retroactive application. It found that Sibley's reliance interest outweighed that of other parties, the new liability was drastically different from prior regulations, and imposing the burden retroactively was inequitable and lacked moderating provisions. Consequently, the court ruled that the retroactive application of MPPAA violated Sibley's Fifth Amendment due process rights, granting Sibley's motion for summary judgment and denying the defendants' cross-motions.

MPPAAERISAWithdrawal LiabilityRetroactive LegislationDue ProcessFifth AmendmentSummary JudgmentPension FundsConstitutional LawMultiemployer Plans
References
7
Case No. MISSING
Regular Panel Decision
Mar 31, 1989

Cutler v. Travelers Insurance

This opinion addresses a class action involving consolidated cases where plaintiffs, acting as class representatives, seek retroactive recovery of attorneys' fees and expenses from defendant workers' compensation carriers. The central issue is whether the holding in Matter of Kelly v State Ins. Fund (1983), which redefined equitable apportionment of litigation expenses under Workers’ Compensation Law § 29 (1) to include future compensation benefits, should be applied retroactively. Defendants argued against retroactivity, asserting that previously settled or adjudicated claims should not be reopened. The court, citing precedents such as Gurnee v Aetna Life & Cas. Co. (1982) and Becker v Huss & Co. (1977), determined that the amendment to Workers’ Compensation Law § 29 (1) merely clarified an existing statute rather than creating new liability, thereby supporting retroactive application similar to Kurcsics. Distinguishing the case from Ianielli v North Riv. Ins. Co. (1986), where a formal general release was involved, the court found that the instant cases lacked prior adjudication of contested issues or a general release, warranting retroactivity of the Kelly decision. Consequently, the court denied the defendants' motions for summary judgment, concluding that triable issues of fact existed.

RetroactivityWorkers' CompensationSummary JudgmentClass ActionLitigation ExpensesAttorneys' FeesEquitable ApportionmentInsurance LienFuture BenefitsStatutory Interpretation
References
11
Case No. MISSING
Regular Panel Decision

Tarango v. Liberty Mutual Fire Insurance Co.

This opinion addresses an appeal from a take-nothing summary judgment that dismissed a bad faith insurance claim denial suit due to the two-year statute of limitations. The central legal question revolves around the retroactive application of a change in the interpretation of the statute of limitations. The Appellant argued against retroactivity, citing fairness and policy. The court analyzed prior rulings, particularly Liberty Mutual Fire Insurance Company v. Richards, and disagreed with the Houston Court of Appeals' assertion of being strictly bound by general retroactivity rules. Ultimately, the court interpreted the Supreme Court's "writ denied" notation in Richards as an implicit confirmation that the general rule of retroactive application for changes in limitation interpretations should apply to all pending cases. Therefore, the trial court's judgment was affirmed.

bad faith insurancestatute of limitationsretroactive applicationsummary judgmentappellate lawjudicial interpretationinsurance claim denialTexas lawlegal precedentwrit denied
References
8
Case No. 03-20-00076-CV
Regular Panel Decision
Jun 30, 2021

Brazos River Authority and the State of Texas v. City of Houston And Sylvester Turner, in His Official Capacity as Mayor of the City of Houston

In this dissenting opinion, Justice Goodwin addresses the case involving H.B. 2846, which mandated the City of Houston to transfer its interests in the Allens Creek Reservoir project to the Brazos River Authority. The City challenged the law's constitutionality on grounds including retroactivity, a local law, and a forced sale. The trial court and the Court of Appeals' majority affirmed the City's position, deeming H.B. 2846 unconstitutionally retroactive. Justice Goodwin dissents, contending that the City, as a municipal corporation, did not demonstrate that its prior right to the water permit constituted a vested property right against the State, which is a necessary condition to invoke the constitutional prohibition against retroactive laws. The dissent concludes that the City's unperfected water permit rights do not meet this threshold, thus H.B. 2846 should not be deemed unconstitutional on retroactivity grounds.

Constitutional LawRetroactivityVested RightsWater RightsMunicipal CorporationsLegislative ControlProperty RightsPublic UseTexas Court of AppealsGovernmental Immunity
References
50
Case No. MISSING
Regular Panel Decision

Metropolitan Life Insurance v. Durkin

The plaintiff, Metropolitan Life Insurance Company, initiated an action seeking a declaration that sections 213 and 213-a of the New York State Insurance Law prohibited the retroactive payment of a wage increase. This increase of $2.85 per week was awarded by the National War Labor Board to its insurance agents, dating back to the start of arbitration proceedings. The plaintiff argued these statutes, designed to prevent excessive post-facto compensation, made such retroactive payments unlawful. However, the trial court and Appellate Division, whose decision was affirmed, concluded that the statutes were not intended to interfere with the common practice of collective bargaining and arbitration, which frequently involves retroactive wage adjustments. The court emphasized that the legislative intent behind the insurance laws was to curb abuses like bonuses and gratuities, not to hinder ordinary and orderly wage-fixing mechanisms, thereby affirming the legality of the retroactive wage increase.

Insurance RegulationRetroactive CompensationCollective Bargaining DisputesWage Arbitration AwardNew York Insurance LawLabor Relations BoardStatutory InterpretationAppellate Court RulingEmployee Benefits LitigationContractual Agreements
References
5
Case No. No. 07-87-0137-CR
Regular Panel Decision

Grimes v. State

Judge Baird dissents from the majority's decision regarding the retroactive application of Tex.Code Crim. Proc.Ann. art. 44.29(b). He argues that the Texas Constitution's Article I, Section 16, which prohibits 'retroactive law,' is broader than the federal ex post facto clause and applies to criminal cases, not just civil matters. Baird contends that the retroactive application of Article 44.29(b) unconstitutionally deprives the appellant of a vested right to a new trial for errors in the punishment phase, a right the appellant likely relied upon for trial strategy. He also disputes the majority's assertion that the retroactive law prohibition does not apply to statutes merely affecting procedural matters, arguing that a procedural label does not immunize a law from scrutiny if it affects substantial rights. Furthermore, Baird states that Tex.Gov't Code Ann. § 311.022 mandates prospective operation unless a statute is expressly made retrospective, which is not the case for Article 44.29(b).

Ex post factoRetroactive lawTexas Constitution Article I Section 16Criminal procedurePunishment phaseVested rightsTrial strategyStatutory interpretationAppellate reviewJudicial dissent
References
18
Case No. M2006-00109-COA-R3-JV
Regular Panel Decision
Jun 05, 2007

Christy L. Taylor v. Randall Robinson, Jr.

The mother of a twelve-year-old boy filed a petition to establish paternity, which DNA testing confirmed. The trial court deviated from child support guidelines, ordering retroactive support only from the petition filing date due to the mother's failure to inform the father of possible paternity. The Court of Appeals affirmed the trial court's decision regarding the deviation from retroactive child support. However, the case was remanded for the trial court to include the total amount of retroactive support that would have been owed had no deviation been made, as required by statute.

PaternityChild SupportRetroactive SupportDeviationParental NotificationDNA TestingLegitimation PetitionEquitable ConsiderationsAppellate ReviewRemand
References
3
Case No. M2003-00629-COA-R3-JV
Regular Panel Decision
Oct 15, 2004

Linda C. Gorrell v. Tyree B. Harris, IV

This is a child support modification appeal where Linda C. Gorrell sought to modify a settlement agreement with Tyree B. Harris, IV. The Court of Appeals affirmed that the private agreement was void as against public policy, modifying the trial court's decision. It ruled that child support, both prospective and retroactive, must conform to Tennessee Child Support Guidelines, reversing the trial court on retroactive support calculation. The court also mandated an upward deviation for prospective support due to the father's lack of visitation, despite the mother's antagonistic conduct, but denied retroactive upward deviation. The case was remanded for recalculation and determination of attorney fees.

Child SupportModificationPaternitySettlement AgreementVoid ContractPublic PolicyTennessee Child Support GuidelinesRetroactive SupportProspective SupportUpward Deviation
References
29
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