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Case Law Database

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

Case No. MISSING
Regular Panel Decision

Capozzi v. Whitman

This case involves an Article 78 application for a writ of prohibition against a Justice of the Municipal Court. The petitioner, acting as a landlord, sought to prevent the Municipal Court from vacating a final order and warrant of eviction previously issued in a summary proceeding. The tenant had moved to set aside the final order, citing fraud or mistake. The court ruled that it possesses inherent power to vacate its own judgments or final orders in the interest of justice. Furthermore, the petitioner was found to have an adequate remedy through appeal. Consequently, the cross-motion was granted, and the proceeding for a writ of prohibition was dismissed.

Article 78Writ of ProhibitionSummary ProceedingVacating Final OrderInherent Court PowerAppellate RemedyLandlord-Tenant DisputeFraudNewly Discovered EvidenceMunicipal Court
References
5
Case No. WR-80,923-02
Regular Panel Decision
Jun 01, 2015

Harris, Roderick

Roderick Harris, a death row inmate, sought a writ of prohibition to prevent the disclosure of his trial files, which were ordered by the trial court in response to his ineffective assistance of counsel claims. The State of Texas filed a response, arguing that Harris's claims waived attorney-client and work-product privileges, thereby justifying the disclosure order. The State contended that the trial court possessed the discretion under Article 11.071 of the Code of Criminal Procedure to compel discovery of relevant files. It requested the Court of Criminal Appeals deny Harris's motion, emphasizing that the scope of waiver for privileged information is determined by the trial court based on relevancy to the ineffective assistance claims. The case highlights a dispute over the balance between a defendant's privilege and the state's need for evidence in habeas corpus proceedings.

Capital MurderWrit of ProhibitionHabeas CorpusIneffective Assistance of CounselAttorney-Client PrivilegeWork-Product PrivilegeDiscovery OrderTrial FilesRestraintsExtraneous Offense Evidence
References
70
Case No. MISSING
Regular Panel Decision

New York City Human Resources Administration v. Carey

This case concerns a CPLR article 78 petition in the nature of a writ of prohibition. The petitioner, the City Human Resources Administration (HRA), sought to vacate a Supreme Court order regarding defendant Delgado, who was charged with arson. Delgado was found by two psychiatrists to be an incapacitated person unable to stand trial due to a severe hearing defect. The lower court, misinterpreting CPL article 730, ruled that Delgado's physical incapacity did not fall under the statute and ordered his placement with HRA and the Department of Social Services. The appellate court granted the writ of prohibition, vacating the lower court's order for exceeding its jurisdiction. The court declared Delgado incompetent to stand trial *nunc pro tunc* and committed him to the custody of the New York State Commissioner of Mental Health, clarifying that CPL 730.10 broadly applies to any mental defect causing incapacity, regardless of its source. The decision emphasized that the statute does not distinguish between different sources of disability once a finding of incapacity is made.

Incompetency to Stand TrialWrit of ProhibitionMental IncapacityCriminal Procedure LawJurisdiction DisputeArson Third DegreeDue ProcessCommitment OrderAppellate ReviewPhysical Impairment
References
1
Case No. WR-62,099-03
Regular Panel Decision
Mar 26, 2015

Pruett, Robert Lynn

Robert Lynn Pruett, convicted of capital murder in 2002 for the killing of correctional officer Daniel Nagle, seeks a writ of prohibition to prevent his execution scheduled for April 28, 2015. Pruett maintains his innocence, arguing that his conviction relied on unreliable informant testimony and lacked physical evidence. He pursued post-conviction DNA testing of a disciplinary report found near Nagle's body, but the evidence had degraded due to improper storage in plastic bags, violating state preservation guidelines. Pruett argues that the State's failure to properly preserve this potentially exculpatory evidence violates his Eighth and Fourteenth Amendment rights. He contends that his inability to prove his innocence, stemming from the State's negligence, makes his execution unconstitutional.

Death PenaltyDNA TestingEvidence PreservationWrit of ProhibitionDue ProcessCruel and Unusual PunishmentCapital MurderExculpatory EvidenceForensic ScienceTexas Criminal Law
References
16
Case No. 05-12-01463-CV
Regular Panel Decision
Nov 06, 2012

In re Amos

Heidi Amos, a defendant in a criminal case, successfully moved to recuse the trial judge, Etta Mullin. The assigned judge, Sue Pirtle, granted the recusal. Subsequently, Judge Mullin filed a motion for reconsideration, which Judge Pirtle granted, scheduling a new hearing. Amos petitioned for writs of mandamus and prohibition, arguing Judge Mullin's motion was improper and Judge Pirtle's authority had expired after the initial recusal and case transfer. The court agreed, concluding Judge Mullin had no authority to file for reconsideration and Judge Pirtle lacked the authority to act. The court conditionally granted the writ of mandamus, preventing Judge Pirtle from reconsidering the recusal order, but denied the writ of prohibition.

Judicial RecusalWrit of MandamusWrit of ProhibitionJudicial AuthorityCriminal ProcedureDue Course of LawTrial Judge ImpartialityMotion for ReconsiderationAssigned JudgeInterlocutory Appeal
References
21
Case No. MISSING
Regular Panel Decision

In Re Swift Transportation Co.

Swift Transportation Company, Inc. sought a writ of mandamus to compel the 243rd District Court, Judge David C. Guaderrama, to grant its motion to compel arbitration against employee Jose Valtierra. Valtierra, an over-the-road truck driver for Swift, a non-subscriber to Texas Workers’ Compensation, was injured and received benefits under Swift's Injury Benefit Plan, which contains a mandatory arbitration clause. Valtierra subsequently filed a negligence suit, and Swift moved to compel arbitration. The appellate court denied relief, finding that Swift's Injury Benefit Plan is an employment contract within the meaning of Section 1 of the Federal Arbitration Act (FAA), thus exempting it from FAA coverage. Furthermore, the Texas General Arbitration Act (TAA) was deemed inapplicable because it was a personal injury suit without a signed agreement to arbitrate by counsel. Under Texas common law, the arbitration agreement was found void and unenforceable due to Section 406.033(e) of the Texas Labor Code, which prohibits pre-injury waiver of causes of action for non-subscriber employers.

Arbitration AgreementFederal Arbitration Act ExemptionTexas Arbitration ActTexas Labor CodeEmployment ContractTransportation WorkersWorkers' Compensation Non-subscriberWrit of MandamusMotion to Compel ArbitrationPre-injury Waiver
References
0
Case No. 86-32865
Regular Panel Decision

Kyles v. Anthony

Alice Kyles (relator) sought a writ of prohibition to prevent the respondent from proceeding with a bill of review filed by Associated Indemnity Corporation (AIC). Kyles had previously obtained a default judgment against AIC regarding an erroneous workers' compensation award. AIC attempted to use a nunc pro tunc order to correct the award, but this court had previously ruled that the Industrial Accident Board lacked the authority to make such corrections to a final award. As AIC's bill of review sought to relitigate issues already settled by this Court, the writ of prohibition was granted to prevent the inferior court from entertaining further proceedings.

Workers' CompensationWrit of ProhibitionBill of ReviewNunc Pro Tunc OrderClerical ErrorRes JudicataDefault JudgmentEquitable GroundsMeritorious DefenseTexas Law
References
5
Case No. 5338/93
Regular Panel Decision

Renzulli v. McElrath

The petitioner-mother, Nora Renzulli, sought a writ of prohibition against Family Court Judge Terrence McElrath, claiming the Family Court lacked subject matter jurisdiction over a child custody matter. The Supreme Court, through a Judicial Hearing Officer (JHO) Radin, had previously awarded custody to the mother, though this was not explicitly memorialized in the final divorce judgments. The Family Court assumed jurisdiction under Family Court Act § 651 (b) and awarded temporary custody to the father. The petitioner also sought civil damages against the Family Court Judge. The Supreme Court (Maltese, J.) acknowledged the prior Supreme Court custody award but found the Family Court had concurrent jurisdiction under Family Court Act § 652 (b) because the Supreme Court judgments did not reserve exclusive jurisdiction. Therefore, the motion for a writ of prohibition and the request for damages were denied.

Writ of ProhibitionFamily Court JurisdictionChild CustodyConcurrent JurisdictionJudicial ImmunityChild Support ArrearsMarital DissolutionSupreme CourtProcedural LawChild's Best Interest
References
32
Case No. WR No. 20,644
Regular Panel Decision
Feb 25, 2015

Larson, Paul Allen

Paul Larson, acting pro se, filed a Petition for Writ of Error/Bill of Review with the Texas Court of Criminal Appeals. Larson alleges errors appearing on the face of the record and extrinsic fraud committed by the State in connection with prior Cause Numbers 449008-C, 449008-D, 465007-C, and 465007-D. He specifically claims the State mislabeled a June 12, 2014, answer as 'Original' and intentionally delayed its delivery. Larson seeks a full review of the Habeas Record, an order for the Harris County District Clerk's Office to provide complete files, and for the Court to grant his Bill of Review and the relief originally sought in his Applications for Writ of Habeas Corpus and/or Writ of Mandamus.

Writ of ErrorBill of ReviewHabeas CorpusMandamusFraudError on RecordExtrinsic FraudTexas Court of Criminal AppealsPro SeSupervised Release
References
2
Case No. MISSING
Regular Panel Decision

In re Copeland

Michael Copeland sought a writ of mandamus to compel the district judge to vacate an order forcing arbitration with his employer, Stanley Transportation, Inc., following a work-related injury. Copeland contested the validity and public policy compliance of the arbitration agreement, specifically challenging the trial court's finding that Stanley's employee benefit plan offered benefits comparable to the Texas Workers’ Compensation Act. Citing Lawrence v. CDB Servs., Inc., the court clarified that comparing benefit plan equivalence is not a relevant issue for compelling arbitration. Consequently, as the sole stated basis for the mandamus petition was deemed irrelevant, the Petition for Writ of Mandamus was denied.

Arbitration AgreementMandamusEmployment LawContract ValidityPublic PolicyFederal Arbitration ActTexas LawPreemptionEmployee Benefit PlanAppellate Review
References
5
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