In re J.B. Hunt Transport, Inc.
492 S.W.3d 287
| Tex. | 2016Background
- On Nov. 24, 2014 a J.B. Hunt tractor-trailer struck a disabled Isuzu on I‑10 in Waller County; occupants Jason Williams and Synthea Arms were injured and Williams later died.
- On Dec. 12, 2014 J.B. Hunt filed a Waller County suit against the Isuzu’s owners seeking property-damage relief; service completed Jan. 7–20, 2015.
- On Dec. 22, 2014 the Real Parties (Williams and Arms) sued J.B. Hunt in Dallas County for personal injuries and served defendants Dec. 30, 2014.
- J.B. Hunt filed a plea in abatement in Dallas County asserting the first‑filed Waller County action had dominant jurisdiction; Real Parties asserted exceptions to the first‑filed rule and the Dallas trial court retained jurisdiction.
- The Texas Supreme Court held (1) the two suits were inherently interrelated under the compulsory-counterclaim analysis, (2) the Real Parties failed to prove either the inequitable‑conduct or lack‑of‑bona‑fide‑intent/diligence exceptions, and (3) the Dallas court abused its discretion by denying abatement.
- The Court concluded Prudential controls mandamus availability (displacing Abor’s stricter test) and conditionally granted mandamus directing the Dallas court to grant J.B. Hunt’s plea in abatement.
Issues
| Issue | Plaintiff's Argument (Real Parties) | Defendant's Argument (J.B. Hunt) | Held |
|---|---|---|---|
| Whether the suits are inherently interrelated so dominant‑jurisdiction rules apply | The claims are not compulsory/cannot be the same subject matter | The Dallas claims meet the compulsory‑counterclaim framework and were not the subject of a pending action when Waller suit was filed | Inherent interrelation exists; dominant‑jurisdiction analysis applies (Wyatt framework) |
| Whether J.B. Hunt’s conduct estops it from claiming first‑filed priority (inequitable‑conduct exception) | J.B. Hunt’s post‑crash statements, offers, and communications were deceptive and prevented prompt filing | Any alleged conduct did not cause Real Parties to delay filing; no prejudice shown | Exception not met — Real Parties failed to show causation/prejudice from J.B. Hunt’s conduct |
| Whether J.B. Hunt lacked bona fide intent/diligence in prosecuting its Waller suit (intent/diligence exception) | The Waller suit was a venue‑securing tactic; delays in service show lack of genuine prosecution | J.B. Hunt promptly took prosecutorial steps (emails, inspections, attempted waivers, threat of TRO) and completed service within an acceptable timeframe | Exception not met — Waller filing plus subsequent prosecutorial acts show bona fide intent and diligence (Curtis line) |
| Whether mandamus relief is available for erroneous denial of plea in abatement | Abor’s active‑interference standard limits mandamus; here no active interference, so mandamus should be unavailable | Prudential permits mandamus when a trial court abuses discretion and appellate remedies are inadequate; relief appropriate to avoid wasted litigation | Prudential governs; Abor’s rigid test abrogated for this context. Because the trial court abused discretion, mandamus conditionally granted |
Key Cases Cited
- Wyatt v. Shaw Plumbing Co., 760 S.W.2d 245 (Tex. 1988) (inherent interrelation/first‑filed rule analysis)
- Curtis v. Gibbs, 511 S.W.2d 263 (Tex. 1974) (diligence standard for prosecuting first suit)
- In re Prudential Ins. Co. of Am., 148 S.W.3d 124 (Tex. 2004) (mandamus availability balancing test; adequate‑remedy analysis)
- Abor v. Black, 695 S.W.2d 564 (Tex. 1985) (prior rule limiting mandamus for abatement denials; superseded here)
- Reed v. Reed, 311 S.W.2d 628 (Tex. 1958) (lack of diligence in prosecuting first suit can defeat priority)
- V.D. Anderson Co. v. Young, 101 S.W.2d 798 (Tex. 1937) (inequitable‑conduct/estoppel example)
- Wheeler v. Williams, 312 S.W.2d 221 (Tex. 1958) (inequitable‑conduct exception failed where no fact issues proved)
- Perry v. Del Rio, 66 S.W.3d 239 (Tex. 2001) (first‑filed rule admits exceptions where race to courthouse unfairly run)