Reference Tracker · Texas Business Court
Texas Business Court Cases.
The data
47 verified substantive Texas Business Court opinions. Click column headers to sort.
| Case | Citation | Date | Division | Judge | Topic | Summary |
|---|---|---|---|---|---|---|
| Energy Transfer v. Culberson Midstream | 2024 Tex. Bus. 1 | October 30, 2024 | 1st Div. | Whitehill, J. | Jurisdiction | Granted motion to remand case to district court. Cases filed before September 1, 2024 not removable to Business Court under Section 8 of H.B. 19. |
| Synergy Global v. Hinduja Global | 2024 Tex. Bus. 2 | October 31, 2024 | 1st Div. | Whitehill, J. | Jurisdiction | Granted remand. Pre-September 1, 2024 cases removed to Business Court must be returned to district court. |
| TEMA Oil and Gas v. ETC Field Services | 2024 Tex. Bus. 3 | November 6, 2024 | 8th Div. | Bullard, J. | Jurisdiction | After construing H.B. 19, removal is not permitted for cases filed before September 1, 2024. Sanctions denied. |
| Winans v. Berry | 2024 Tex. Bus. 5 | November 7, 2024 | 4th Div. | Barnard, J. | Jurisdiction | Chapter 25A applies only to cases commenced on or after September 1, 2024. 2022 suit cannot be removed. |
| Lone Star NGL v. EagleClaw Midstream | 2024 Tex. Bus. 8 | December 20, 2024 | 11th Div. | Adrogué, J. | Jurisdiction | Even with post-September 1 written agreement consenting to Business Court jurisdiction, pre-September 1, 2024 cases cannot be heard. Certified for permissive interlocutory appeal. |
| C Ten 31 v. Tarbox | 2025 Tex. Bus. 1 | January 3, 2025 | 3rd Div. | Andrews, J. | Jurisdiction | Section 25A.004(e) incorporates the amount-in-controversy limit of the underlying subsection. Burden-shifting framework on amount-in-controversy challenges adopted. |
| Osmose Utilities v. Navarro County Electric | 2025 Tex. Bus. 3 | January 31, 2025 | 1st Div. | Bouressa, J. | Jurisdiction | Removal of an action means removal of the entire suit, partial removal of individual claims is not permitted. |
| Sebastian v. Durant | 2025 Tex. Bus. 4 | February 4, 2025 | 11th Div. | Sharp, J. | Jurisdiction | Under Section 8 of H.B. 19, an entire civil action commences with the filing of the original petition. Chapter 25A permits removal of an action, not partial removal of individual claims. |
| SafeLease v. Storable | 2025 Tex. Bus. 6 | February 10, 2025 | 3rd Div. | Andrews, J. | Procedure | 30-day period for removal does not begin before the action is filed. An action may satisfy jurisdictional amount-in-controversy minimums even when no party seeks damages. |
| Cypress Town Center v. Kimco Realty | 2025 Tex. Bus. 8 | February 25, 2025 | 11th Div. | Adrogué, J. | Jurisdiction | Joinder of a publicly-traded company after September 1, 2024 does not confer Business Court jurisdiction over a case filed pre-September 1, 2024. |
| Primexx Energy Opportunity Fund v. Primexx Energy Corp. | 2025 Tex. Bus. 9 | March 10, 2025 | 1st Div. | Whitehill, J. | Partnership | Partner fiduciary duties of loyalty and care cannot be eliminated even where the partnership agreement limits them. Addresses drag-along rights and partner obligations. |
| ET Gathering & Processing v. Tellurian Production | 2025 Tex. Bus. 11 | March 11, 2025 | 11th Div. | Barnard, J. | Jurisdiction | Plea to the jurisdiction denied. Defendant did not produce evidence that plaintiff's amount-in-controversy pleading was a sham. |
| Atlas IDF v. NexPoint Real Estate Partners | 2025 Tex. Bus. 16 | May 13, 2025 | 1st Div. | Whitehill, J. | Jurisdiction | Comprehensive opinion on "qualified transaction" under Chapter 25A, when an action "arises out of" a qualified transaction, the relevant period for aggregate value determination, and the burden for establishing the same. |
| Slant Operating v. Octane Energy Operating | 2025 Tex. Bus. 22 | May 23, 2025 | 8th Div. | Bullard, J. | Jurisdiction | Plea to jurisdiction denied. Plaintiff's allegations and defendant's failure to refute met the burden under Section 25A.004(d)(1). |
| Reed v. Rook TX | 2025 Tex. Bus. 23 | June 18, 2025 | 3rd Div. | Andrews, J. | Internal Affairs | Action concerns limited partnership's "governance, governing documents, or internal affairs" under Section 25A.004(b)(2). Section 25A.004(b)(2) applies even where internal affairs are not the predominant focus. |
| Martens v. Lamkin Land & Cattle Co. | 2025 Tex. Bus. 32 | August 14, 2025 | 8th Div. | Stagner, J. | LLC | Business Court has subject-matter jurisdiction over plaintiff's application for involuntary winding-up of an LLC. Dominant jurisdiction doctrine does not apply where prior district court case is not sufficiently interrelated. |
| Chaudhry v. Stillwater Capital Investments | 2025 Tex. Bus. 31 | August 12, 2025 | 1st Div. | Whitehill, J. | Jurisdiction | Comprehensive opinion addressing whether common law and statutory fraud inducing entry into LLC company agreement constitutes "internal affairs"; case-wide amount in controversy encompasses counterclaims. |
| Marathon Oil v. Mercuria Energy | 2025 Tex. Bus. 36 | September 18, 2025 | 11th Div. | Andrews, J. | Contract | Force-majeure dispute under NAESB base-contract. Both transaction confirmations combine with base contract to form a single, integrated agreement. |
| Riverside Strategic Capital v. CLG Investments | 2025 Tex. Bus. 35 | September 17, 2025 | 1st Div. | Whitehill, J. | Limitations | Addresses statute of limitations accrual and the discovery rule for fraudulent statements in securities purchase agreements. |
| Barrett v. Barrett | 2025 Tex. Bus. 37 | September 23, 2025 | 4th Div. | Barnard, J. | Jurisdiction | Claims arising out of Title 9 of the Property Code (trusts) are not within Business Court jurisdiction. Supplemental jurisdiction under Section 25A.004(g) requires agreement of all parties. |
| Arnold v. Blue Ridge Landfill | 2025 Tex. Bus. 38 | October 7, 2025 | 11th Div. | Sharp, J. | Contract | Denying defendant's summary judgment motion. Royalty payment contract interpretation re: revenue from disposal of solid waste partially on and partially off the Property. |
| Marathon Oil v. Mercuria Energy (Winter Storm Uri) | 2025 Tex. Bus. 39 | October 14, 2025 | 11th Div. | Andrews, J. | Contract | Force-majeure dispute arising from Winter Storm Uri. Contract did not obligate seller to purchase gas on spot market or buy back delivery obligation as prerequisite or alternative to declaring force majeure. |
| Marathon Oil v. Mercuria Energy (Liquidated Damages) | 2025 Tex. Bus. 40 | October 28, 2025 | 11th Div. | Andrews, J. | Contract | Fact issues preclude determination of whether liquidated-damages clause is an unenforceable penalty. Defendant's cost-basis theory is not the correct measure of plaintiff's actual damages under the circumstances. |
| Cadence McShane Construction v. Ryan BB-Blockhouse Creek | 2025 Tex. Bus. 43 | November 3, 2025 | 3rd Div. | Sweeten, J. | Jurisdiction | Third-party claims against subcontractors met the "qualified transaction" definition under Section 25A.004(d)(1). Plea to the jurisdiction denied. |
| Lensabl v. RBH SPE One | 2025 Tex. Bus. 44 | November 5, 2025 | 8th Div. | Stagner, J. | Pleading | Rule 91a motion to dismiss granted in part, pleadings fail to state a legally cognizable claim for breach of contract or veil piercing. Fraud claim adequately pleaded. |
| City Choice Group v. TMC Grand Blvd Land Co. | 2025 Tex. Bus. 45 | November 8, 2025 | 11th Div. | Adrogué, J. | Contract | Contract termination notice, termination not subject to "strict compliance" standard applicable to option exercise. Substantial compliance with notice provisions sufficient. Specific performance denied as estopped. |
| CRS Mechanical v. Norfolk Cold Storage | 2025 Tex. Bus. 46 | November 14, 2025 | 8th Div. | Stagner, J. | Construction | Summary judgment granted against counterclaims for declaratory relief. Declarations either duplicated issues already joined or sought relief beyond the Court's jurisdiction. |
| Crain v. Northern (Legal Malpractice) | 2025 Tex. Bus. 49 | December 17, 2025 | 8th Div. | Bullard, J. | Jurisdiction | Legal malpractice and fractured malpractice-based claims dismissed without prejudice for lack of subject-matter jurisdiction. Such claims are not within the Court's authority. |
| Hensarling v. Carmichael | 2025 Tex. Bus. 50 | December 18, 2025 | 4th Div. | Sharp, J. | Partnership | Motion to dismiss under Rule 91a denied. Application to wind up a partnership under Section 11.314 of the Business Organizations Code provided sufficient factual allegations at this early stage. |
| Slant Operating v. Octane Energy (Reciprocal Waiver) | 2025 Tex. Bus. 53 | December 22, 2025 | 8th Div. | Bullard, J. | Contract | Summary judgment granted on competing motions concerning a reciprocal waiver agreement. No genuine issues of material fact existed regarding the definiteness of the agreement's essential terms or mutual assent. |
| Preston Hollow Capital v. Truist Bank (Trust Code) | 2025 Tex. Bus. 55 | December 19, 2025 | 1st Div. | Whitehill, J. | Trust | Trust Code does not bar punitive damages waivers. Waiver in one bond financing contract applies to claims based on a related contract in the same financing. Terminated trustee must protect former beneficiary's confidential information. |
| Quintero v. Urban Infraconstruction (Inaugural Jury Trial) | 2026 Tex. Bus. 3 | January 26, 2026 | 1st Div. | Bouressa, J. | Trial | Ruling after court-ordered Rule 166(g) briefing in the Business Court's first jury trial. Plaintiffs take nothing on certain claims; declaratory relief denied to both sides. Breach of contract, breach of fiduciary duty, and fraud claims proceed to jury trial. |
| Crain v. Northern (Buy-Sell Option) | 2026 Tex. Bus. 4 | February 2, 2026 | 8th Div. | Bullard, J. | Contract | Specific performance ordered under a mandatory Buy-Sell Option clause. Offeror entitled to specific performance after Offeree failed to respond to required notice. Attorneys' fees awarded. |
| Preston Hollow Capital v. Truist Bank (Responsible Third Party) | 2026 Tex. Bus. 5 | February 2, 2026 | 1st Div. | Whitehill, J. | Procedure | Addresses Civil Practice & Remedies Code Chapter 33's definition of "responsible third party" and the meaning of "the harm for which recovery of damages is sought." |
| Alamo Title v. WFG National | 2026 Tex. Bus. 6 | February 3, 2026 | 4th Div. | Sharp, J. | Jurisdiction | Removal notice pleading more than $5M in controversy satisfied jurisdictional threshold absent rebutting evidence. Aiding-and-abetting breach of fiduciary duty and IP-related allegations invoked Section 25A.004 jurisdictional clauses. |
| American Airlines v. JetBlue Airways | 2026 Tex. Bus. 7 | February 19, 2026 | 8th Div. | Bullard, J. | Jurisdiction | Defendant's special appearance denied. Court has specific personal jurisdiction over defendant. |
| BNSF Railway v. Level 3 Communications | 2026 Tex. Bus. 8 | February 24, 2026 | 1st Div. | Bouressa, J. | Arbitration | Arbitration award confirmed. Parties' contract and applicable law gave the arbitration panel authority to decide both substantive and procedural arbitrability questions. |
| Yaun v. Battle & Sands Energy (HB 40 Retroactivity) | 2026 Tex. Bus. 9 | March 3, 2026 | 11th Div. | Dorfman, J. | Jurisdiction | HB 40's $5M amount-in-controversy threshold applies retroactively to civil actions commenced on or after September 1, 2024. Motion to remand denied. |
| Crain v. Northern (Derivative Standing) | 2026 Tex. Bus. 11 | March 11, 2026 | 8th Div. | Bullard, J. | Derivative | Plea to the jurisdiction granted against derivative claims. Plaintiff lacked standing because he was no longer a member of the entities when he filed suit, per TBOC § 101.463. |
| Galderma Laboratories v. Brenner | 2026 Tex. Bus. 12 | March 12, 2026 | 8th Div. | Stagner, J. | Non-Compete | Temporary injunction granted against former employee's breach of non-compete agreement; scope of services reformed. Temporary injunction denied for customer non-solicit, worker non-solicit, confidentiality, and TUTSA claims. |
| GoSecure v. CrowdStrike | 2026 Tex. Bus. 13 | March 13, 2026 | 3rd Div. | Andrews, J. | Jurisdiction | CrowdStrike's special appearance granted. Court lacks general jurisdiction (CrowdStrike not "essentially at home" in Texas despite large office and sales). Specific jurisdiction lacking because claims don't arise out of or relate to Texas contacts. |
| May v. INEOS USA Oil & Gas | 2026 Tex. Bus. 14 | March 27, 2026 | 4th Div. | Sharp, J. | Oil & Gas | Partial summary judgment on oil & gas lease interpretation. Contracts conveyed fee simple determinable; earned-acreage provisions operate as special limitations on property interest; 30% reversionary back-in interest triggered at Payout. |
| Dallas Sports Club v. DSE Hockey Arena (Mavericks v. Stars) | 2026 Tex. Bus. 15 | April 2, 2026 | 1st Div. | Whitehill, J. | Contract | 90-page opinion resolving seven summary judgment motions in Dallas Mavericks v. Dallas Stars franchise/location dispute. Contract construction across four contracts among three parties; Mavericks' claims survive on contract-construction grounds. |
| Daimler Truck Financial Services v. Vanguard National Trailer | 2026 Tex. Bus. 16 | April 8, 2026 | 8th Div. | Bullard, J. | Jurisdiction | Certain defendants' special appearance granted. Plaintiff failed to establish that its claims against them arose out of their Texas conduct in this lien-priority dispute involving trailer manufacturer fraud allegations. |
| Energy Founders Fund v. Daskevich (Advancement) | 2026 Tex. Bus. 17 | April 9, 2026 | 11th Div. | Stagner, J. | Indemnification | Motion to compel advancement of legal fees against third-party defendant denied. Claims were not brought "by reason of" his service as a director as required by the third-party defendant's company agreement. |
| Energy Founders Fund v. Daskevich (Drag-Along) | 2026 Tex. Bus. 18 | April 10, 2026 | 11th Div. | Stagner, J. | Governance | Summary judgment granted. Company agreement required only majority board approval to transfer membership units; it did not also require consent of two directors. |
| Enosis Investments v. Jensen | 2026 Tex. Bus. 19 | April 23, 2026 | 3rd Div. | Andrews, J. | LLC | Rule 166(g) ruling on fiduciary duties. Pleadings did not support joint venture (no agreement to share profits/losses). A non-managing member of a manager-managed LLC generally does not owe fiduciary duties; corporate manager's fiduciary duty is not passed through to its individual officers/owners absent piercing. |
Last updated: May 12, 2026
Methodology and sources
What's included
This tracker includes substantive Texas Business Court opinions, those resolving merits issues, novel jurisdictional questions, or significant procedural matters with broader precedential value. Pure procedural rulings (routine motions to remand for pre-September 1, 2024 cases, after the foundational rulings established the rule; routine special-appearance grants; routine motions to compel) are generally omitted to keep the tracker focused on citable precedent.
All entries verified against the official opinions list at txcourts.gov/businesscourt/opinions/. Citations follow the court's preferred format (e.g., 2025 Tex. Bus. 9, paragraph numbers preferred over page numbers).
Court structure
The Texas Business Court has 11 divisions corresponding to the state's Administrative Judicial Regions. As of mid-2026, five divisions are operational: 1st (Dallas/McKinney), 3rd (Austin), 4th (San Antonio), 8th (Fort Worth), and 11th (Houston). The remaining divisions await legislative funding. Two judges are appointed per division to two-year terms.
Maintained by
Compiled by Kraus Law PLLC as a public reference. Corrections or additions welcome at hello@kraus.law.
Patterns and observations
What the first 19 months of Business Court opinions reveal.
5
Substantive opinions in 2024 (Sept-Dec), foundational jurisdictional rulings
26
In 2025, substantive merits decisions ramping up
16
In 2026 to date, bench trials, jury trials, complex merits decisions
5
Operational divisions (1st, 3rd, 4th, 8th, 11th), 6 remaining await funding
Phase one: foundational jurisdictional rulings
The first six months produced a clear pattern: cases filed before September 1, 2024 cannot be removed to the Business Court, regardless of party consent. This rule was established across multiple opinions (Energy Transfer v. Culberson Midstream, Synergy Global v. Hinduja, TEMA Oil and Gas v. ETC Field Services, Winans v. Berry) and continues to control. Section 8 of H.B. 19 was the dispositive provision.
Phase two: "qualified transaction" jurisprudence
Throughout 2025, opinions interpreted Section 25A.004, particularly the "qualified transaction" requirement, amount-in-controversy thresholds, and how internal-affairs claims fit. The Atlas IDF v. NexPoint Real Estate Partners opinion (May 2025) is the comprehensive reference on qualified-transaction analysis. HB 40 (effective September 1, 2025) lowered the threshold from $10M to $5M and was held retroactive for cases filed on or after September 1, 2024 (Yaun v. Battle & Sands).
Phase three: substantive merits and trial activity
Early 2026 marked a transition to substantive merits work. The first bench trial completed; the first jury trial (Quintero v. Urban Infraconstruction) began but ended in a directed verdict for the defendant after plaintiffs' case-in-chief. The Mavericks v. Stars opinion (April 2026), a 90-page contract construction tour-de-force, and the Marathon Oil v. Mercuria Energy force-majeure trilogy demonstrate the court producing the kind of detailed, reasoned commercial opinions Texas legislators intended.
Notable opinion clusters
Several cases produced multiple opinions over time as litigation progressed, Marathon Oil v. Mercuria Energy (4 opinions on force majeure, contract construction, liquidated damages); Primexx Energy v. Primexx Energy Corp. (5 opinions on partnership duties, drag-along rights, jurisdiction); Crain v. Northern (3 opinions on buy-sell specific performance, malpractice jurisdiction, derivative standing); Slant Operating v. Octane Energy (4 opinions). These threads provide useful longitudinal views of how the court handles complex cases.
Author concentration
Three judges have authored a disproportionate share of substantive opinions: Whitehill, J. (1st Div., Dallas), Bullard, J. (8th Div., Fort Worth), and Andrews, J. (3rd Div., Austin). Each has developed identifiable interpretive styles worth attorney attention when forum selection or removal decisions are being made.
Related reading and listening
Companion content on the Texas Business Court, SB 29 governance reforms, and the broader Texas business law framework.
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