Supreme Court

23-0634 - First Sabrepoint Cap. Mgmt., L.P. v. Farmland Partners Inc.

First Sabrepoint Cap. Mgmt., L.P. v. Farmland Partners Inc.

Case number: 23-0634
Legal category: Texas Citizens Participation Act
Subtype: Timeliness of Trial Court's Ruling
Set for oral argument: January 16, 2025

Case Summary

The central issue in this appeal is whether a trial court has the authority to grant a motion to dismiss under the Texas Citizens Participation Act after the motion has been denied by operation of law.

After an investment researcher published an article about Farmland Partners, Farmland alleged that the article was defamatory and caused its stock price to decline. Accusing Sabrepoint of participating with the researcher to manipulate the securities market and profit from the stock‑price decline, Farmland sued in Colorado state court. The case was removed to federal court, and the court dismissed the suit for lack of personal jurisdiction. Farmland then filed suit in Texas state court. Sabrepoint moved to dismiss the suit under the TCPA because the article was protected speech. Sabrepoint also moved for summary judgment based on collateral estoppel, arguing that the federal court determined in its jurisdictional decision that Sabrepoint was not involved with the article. The trial court granted both motions, and Farmland appealed.

The court of appeals determined that the TCPA order is void and not appealable because the motion was initially denied by operation of law under the TCPA when the trial court did not rule within thirty days of the hearing on that motion. The court then reversed the summary judgment, concluding that Sabrepoint has not established that collateral estoppel applies, and it remanded the case to the trial court.

Sabrepoint petitioned for review, arguing that (1) the trial court had authority to grant the TCPA motion outside the thirty‑day statutory window and (2) the court of appeals erred in reversing the summary judgment. The Supreme Court granted the petition.

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