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Dissent Argues Business Court Correctly Applied Rule 91a Standard in Attorney Immunity Case
In a dissent from a mandamus proceeding reviewing Business Court Division 11B's denial of a Rule 91a motion to dismiss, an appellate judge argues that the majority improperly lowered the threshold for dismissal when evaluating attorney immunity as a defense to tortious interference claims. Taking the plaintiff's allegations as true—that Jackson sought to oust Reynolds's CEO to secure the position for himself—the dissent concludes the Business Court properly denied dismissal because the pleadings preclude any finding that Jackson's conduct qualifies for attorney immunity as a matter of law.
Justice Farris
Attorney Immunity Bars Tortious Interference Claims Against General Counsel Advising on CEO Termination
The Fifteenth Court of Appeals granted mandamus relief to Frank Jackson, a general counsel sued for tortious interference with a former CEO's $350 million employment contract, holding that advising a multi-billion-dollar company on terminating its CEO falls squarely within the attorney-immunity defense. The court rejected the plaintiff's attempt to recharacterize Jackson's conduct as "business advice" rather than legal representation, emphasizing that the immunity analysis turns on whether the conduct is "the kind" attorneys undertake while discharging professional duties, not on how a nonclient labels it.
Chief Justice Brister
Fifteenth Court of Appeals Denies Mandamus Relief in Socket Solutions Merger Successor Dispute
The Fifteenth Court of Appeals denied mandamus relief to Socket Solutions, LLC, as successor by merger to SS Newco-1 LLC, in an original proceeding challenging a ruling from Business Court Division 11B of Harris County. The per curiam memorandum opinion provides no reasoning for the denial, leaving the underlying Business Court order intact.
Fifteenth Court of Appeals Denies Mandamus Relief in Socket Solutions, Lifting Administrative Stay on Business Court Proceedings
The Fifteenth Court of Appeals denied Socket Solutions, LLC's petition for writ of mandamus in an original proceeding arising from Business Court Division 11B of Harris County, dismissing the relator's emergency temporary relief request as moot and lifting an administrative stay that had been in place since May 15, 2026. The terse memorandum opinion provides no substantive analysis, offering no insight into the nature of the dispute or the grounds for denial.
Fifteenth Court of Appeals Dismisses First Reported Derivative Action Appeal from Business Court Following Joint Settlement Motion
In Firoz Dhamani v. Mustapha Oulad-Chikh, derivatively on behalf of Global Real Estate, LLC, the Fifteenth Court of Appeals granted a joint motion to dismiss with prejudice an appeal from Business Court Division 1A of Travis County. The March 26, 2026 memorandum opinion resolved an appeal from a May 23, 2025 order in a derivative action involving Global Real Estate, LLC.
Fifteenth Court of Appeals Denies Mandamus Challenging Business Court Order in Foundation Dispute
The Fifteenth Court of Appeals denied a mandamus petition filed by three Highland foundations seeking to overturn a September 18, 2025 order issued by Judge William Whitehill of Business Court Division 1B in Dallas County. The per curiam opinion, issued by a panel consisting of Chief Justice Brister and Justices Field and Farris, held that relators failed to establish entitlement to mandamus relief in their dispute with Mark Patrick and several charitable foundation entities.
Fifteenth Court of Appeals Denies Mandamus Challenging Business Court Trial Setting in Minerals Dispute
The Fifteenth Court of Appeals denied a mandamus petition filed by Nicholas Kreines, David P. Ryan, and Liberty Mineral Partners LLC seeking to set aside Business Court Division 3B Judge Patrick K. Sweeten's January 29, 2026 order in ES3 Minerals, LLC v. Kreines. The court held that relators failed to establish entitlement to mandamus relief and denied their emergency motion to stay trial commencement.
Business Court Retains Authority to Reconsider Remand After Plaintiff Amends to Eliminate Jurisdictional Claims
In In re ColossusBets Limited, the Fifteenth Court of Appeals denied mandamus relief to defendants challenging the Business Court's remand order after plaintiff Jerry Reed amended his lottery-rigging claims to eliminate all allegations implicating the court's statutory jurisdiction over internal affairs and governance. The court framed the central issue as whether removal to the Business Court operates as a "one-way door" that prevents reconsideration even when a plaintiff eliminates all jurisdictional predicates through amended pleadings.
Chief Justice Brister Dissents on Transferred-Case Review Standards and Plenary Power in Business Court Appeal
In a dissenting memorandum opinion from the Fifteenth Court of Appeals reviewing a temporary injunction bond dispute transferred from district court to the Business Court, Chief Justice Brister argued that appellate review cannot be split between pre-transfer and post-transfer rulings and that the Business Court need not formally adopt previous orders to exercise plenary power over them. Brister would have declined to remand for further proceedings given an imminent trial date of December 8, 2025, arguing the case should simply proceed to trial.
Business Court Modification of Temporary Injunction Fails Rule 684 Bond Requirement in Non-Compete Dispute
The Fifteenth Court of Appeals reversed in part a Business Court order modifying a temporary injunction against former ES3 Minerals employees and their competing venture, holding that the injunction bond failed to adequately protect appellants' interests under Rule 684 and that the order lacked adequate specificity regarding enjoined subsidiaries. The court also held that challenges to portions of the injunction imposed by the original district court—but not reviewed or reimposed by the Business Court—were not properly before it on appeal.
Appellant's Voluntary Dismissal of Interlocutory Appeal Highlights Strategic Considerations in Business Court Appeals
In Buc-ee's, Ltd. v. Head Country, LLC, the Fifteenth Court of Appeals granted Buc-ee's motion to dismiss its own interlocutory appeal from Business Court Division 11A of Harris County under Texas Rules of Appellate Procedure 42.1(a)(1) and 43.2(f). The November 18, 2025 memorandum opinion represents one of the earliest appellate filings from the new Texas Business Court system, showing that voluntary dismissal procedures apply to Business Court interlocutory appeals.
Voluntary Dismissal Terminates Early Business Court Appeal in NGL Water Solutions v. Lime Rock
The Fifteenth Court of Appeals granted NGL Water Solutions Permian, LLC's unopposed request for voluntary dismissal, terminating appeal No. 15-25-00098-CV from Business Court Division 11B in Harris County. The November 18, 2025 memorandum opinion dismissed the appeal under Texas Rules of Appellate Procedure 42.1(a)(1) and 43.2(f) without reaching the merits of the underlying dispute with Lime Rock Resources entities.
Fifteenth Court Confirms Business Court Jurisdiction Over Pre-Effective-Date Cases with Party Consent Under HB 40 Amendments
In Lone Star NGL Product Services LLC v. EagleClaw Midstream Ventures LLC, the Fifteenth Court of Appeals vacated the Business Court's remand order after determining that House Bill 40's amendments mean Section 8 of House Bill 19 is not a jurisdictional limitation when parties agree to remove a civil action commenced before September 1, 2024, and the case otherwise meets jurisdictional requirements. The appellate court remanded to the Business Court after the parties obtained permission to proceed under Section 25A.021, addressing a transitional question about pre-effective-date cases.
Justice Field
Fifteenth Court of Appeals Dismisses Unopposed Mandamus Petition from Business Court Division 3A in Self-Storage Software Dispute
The Fifteenth Court of Appeals granted an unopposed motion to dismiss a mandamus petition filed by six self-storage software and services companies—Storable, Inc.; RedNova Labs, Inc. (d/b/a storEDGE); SitelinkSoftware, LLC; Easy Storage Solutions, LLC; Bader Co.; and Property First Group, LP—challenging a ruling from Business Court Division 3A in Travis County. The October 2, 2025 memorandum opinion provides no substantive analysis of the underlying dispute or the reasons for dismissal.
Voluntary Dismissal Ends First Reported Appeal from Business Court Division 3A
The Fifteenth Court of Appeals granted an unopposed motion to dismiss the appeal in Storable, Inc. v. Safelease Insurance Services, LLC, a case originating from Business Court Division 3A in Travis County. The October 2, 2025 per curiam memorandum opinion provides no substantive analysis, leaving the underlying Business Court ruling undisturbed following voluntary dismissal under Texas Rule of Appellate Procedure 42.1(a).
Fifteenth Court of Appeals Denies Mandamus Challenging Business Court Discovery Order in Commercial Real Estate Finance Dispute
The Fifteenth Court of Appeals denied a mandamus petition filed by Silver Star Properties REIT, Inc. and three affiliated LLCs seeking to overturn an August 11, 2025 order by Judge Brian Stagner of Business Court Division 8B in Tarrant County. The court held that relators failed to establish entitlement to mandamus relief and denied their accompanying emergency stay motion, leaving Judge Stagner's order intact.
Interlocutory Appeal of Special Appearance Order Dismissed After Merger into Final Judgment
The Fifteenth Court of Appeals dismissed an interlocutory appeal by Primexx Energy Opportunity Fund entities challenging a Business Court order granting special appearances after the appellants notified the court that the interlocutory order had merged into a final judgment now subject to separate appeal under cause No. 15-25-00120-CV. The dismissal illustrates the application of merger doctrine when a trial court renders final judgment while an interlocutory appeal remains pending.
Fifteenth Court of Appeals Denies Mandamus Seeking Interlocutory Review of Business Court Discovery Order
The Fifteenth Court of Appeals issued a memorandum opinion in mandamus proceedings brought by Faisal Chaudhry and Stillwater OZ Development Fund, LLC, challenging a trial court order in what appears to be Business Court litigation. The decision represents an early data point in the developing appellate jurisprudence governing interlocutory review of Texas Business Court rulings.
Fifteenth Court Holds 'Action' Means Entire Lawsuit, Not Individual Claims, for Business Court Removal Eligibility
The Fifteenth Court of Appeals denied mandamus relief to relators seeking to remove derivative claims filed in December 2024 from a divorce action commenced in July 2024, holding that the term "civil action" in the Business Court Act's effective-date provision refers to the entire lawsuit—not individual claims added later—and thus the Act does not apply to any part of a case filed before September 1, 2024. The decision reinforces In re ETC Field Services and rejects arguments that later-added commercial claims could be severed and removed as a separate "action."
Amended Petition Adding Publicly Traded Party After September 1, 2024 Does Not 'Commence' New Action for Business Court Jurisdiction
The Fifteenth Court of Appeals denied mandamus relief to Kimco entities seeking to keep their case in the Business Court after being added as defendants via third-amended petition in September 2024, holding that a civil action 'commences' when originally filed, not when an amended petition adds a publicly traded company. The court rejected relators' argument that adding a publicly traded defendant after the September 1, 2024 effective date triggers Business Court jurisdiction, reaffirming its holding in In re ETC Field Services that removal or amendment does not commence a new civil action.
Business Court Remand Orders Are Not Immediately Appealable, Fifteenth Court Holds
The Fifteenth Court of Appeals dismissed ETC Field Services' direct appeal from a Business Court remand order, holding that no statute authorizes interlocutory appeal of such orders and that remand orders are not final judgments. The court noted that a 2021 business court bill expressly authorized interlocutory appeals from remand orders but the enacted Chapter 25A omitted that provision, and the Legislature clearly knew how to draft such authorization but chose not to do so.
Removal Statute Does Not Apply to Pre-Effective Date Cases: Business Court Lacked Authority to Accept 2017-Filed Action
The Fifteenth Court of Appeals denied mandamus relief in In re ETC Field Services, holding that the Business Court properly remanded a 2017-filed breach of contract action because HB 19's removal provisions apply only to "civil actions commenced on or after September 1, 2024"—and removal transfers rather than commences an action. The court rejected ETC's attempt to remove a seven-year-old case just months before trial, establishing that the Legislature's choice of "commenced" forecloses removal of cases filed in district court before the Business Court's creation.
Mandamus Denied in Challenge to Business Court's Remand of Pre-Effective-Date Case
The Fifteenth Court of Appeals denied Synergy Global Outsourcing's mandamus petition challenging the Business Court's remand order, leaving in place the trial court's determination that it lacked jurisdiction over a case filed before the September 1, 2024 effective date. The brief memorandum opinion relies entirely on the court's reasoning in a companion case decided the same day, In re ETC Field Services, LLC.
Business Court Remand Orders Are Not Immediately Appealable, Fifteenth Court Holds in Second Jurisdictional Dismissal
The Fifteenth Court of Appeals dismissed Synergy Global Outsourcing's appeal from a Business Court Division 1B order remanding the case back to district court, holding that remand orders are neither final judgments nor subject to interlocutory appeal under any statute. The ruling, which follows the court's same-day decision in ETC Field Services, forecloses direct appeals from Business Court determinations that a case does not qualify for the specialized tribunal.
Energy Transfer and Culberson Midstream Parties Jointly Dismiss First Appellate Challenge to Business Court Division 1B
The Fifteenth Court of Appeals granted a joint motion to dismiss the appeal in Energy Transfer LP v. Culberson Midstream LLC, an early case from the Texas Business Court Division 1B. The February 6, 2025 memorandum opinion provides no substantive analysis, with the parties invoking Texas Rule of Appellate Procedure 42.1 to terminate the appeal by agreement.
Energy Transfer Mandamus Proceeding Dismissed by Joint Motion Before Fifteenth Court
Energy Transfer LP and ETC Texas Pipeline, Ltd. jointly moved to dismiss their mandamus petition before the Fifteenth Court of Appeals, and the court granted the motion on February 6, 2025. The per curiam opinion terminates the original proceeding without reaching any merits, leaving the underlying dispute and reasons for dismissal undisclosed in the public record.