First Annual Review: Top Texas Business Court Opinions of 2025
Ten opinions selected for what they decided, five more selected by a computed rule anyone can rerun, from the Business Court's first full calendar year. Selection criteria stated up front. No claim that this list is complete.
Maintained by Charles R. Kraus, licensed in Texas, Minnesota, and Alberta. First published August 26, 2026, covering calendar year 2025. Part of the Texas Business Court Annual Review.
What this is
This is the first edition of a standing annual review. Each January going forward, I intend to publish a review of the prior calendar year's most consequential Texas Business Court opinions, selected against the same disclosed criteria and drawn from the same coded dataset behind the Texas Business Court Performance Report. This first edition covers all of calendar 2025 and publishes now, in August 2026, rather than waiting for a clean January cycle, because the 2025 docket was substantially complete well before then and there was no reason to sit on it. Every edition after this one is intended to publish in January, covering the year just closed.
The index for every edition, current and future, lives at the Annual Review's permanent page. A missing year there would be conspicuous by a missing number. That is the point of maintaining an index at all.
How these fifteen opinions were selected
Two criteria, applied separately and disclosed separately, rather than one blended and unstated standard.
The qualitative ten. A decision earns a spot on this list if it meaningfully changed how the Business Court handles a recurring question, or provided clarity a practitioner can actually use on an issue relevant to Texas corporate and commercial litigation. This is not a claim that these are objectively the ten most important opinions of 2025. It is a disclosed editorial judgment, not a formula, and I would rather say so than dress a judgment call up as an algorithm.
The computed five. Alongside the qualitative list, I ran one reproducible query against the firm's own coded dataset: which 2025 matters took the longest from motion filing to ruling. This criterion has no editorial judgment in it at all. Anyone with the dataset can rerun it and get the same five matters. I have not found precedent elsewhere for using time-to-disposition as a case-selection criterion in a year-in-review publication; as far as I can tell, this is an original methodological choice on my part, not a borrowed convention, and I am stating that plainly rather than implying it is standard practice.
Fifty-five of the 123 opinions coded as of this edition were decided in calendar 2025. The dataset records citation, division, judge, matter type, disposition, and, where the opinion itself recites both dates, the days elapsed from motion to ruling. Two entries below carry a stated medium confidence rather than high, reflecting either a secondary rather than primary source or a coding note in the underlying record; both are disclosed in the entry itself, not smoothed over.
The legislative backdrop
Two statutes shaped what the Business Court could decide in 2025. Senate Bill 29, effective May 14, 2025, codified the business judgment rule for Texas corporations for the first time. House Bill 40, effective September 1, 2025, expanded the court's jurisdiction and lowered the general amount-in-controversy threshold from $10 million to $5 million. Neither statute produced a case on this list by itself, but House Bill 40's effective date runs directly through two of the ten selected opinions below, entries six and seven, which involve the same two parties on opposite sides of that exact date.
The ten selected opinions
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No. 1
Osmose Utilities Doo v. Navarro County Electric Cooperative · 2025 Tex. Bus. 3
Court held Chapter 25A allows removal of entire suits only, not individual claims, and that the suit's 2022 commencement date fell before H.B. 19 took effect, requiring remand for lack of jurisdiction.
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No. 2
Sebastian v. Durant · 2025 Tex. Bus. 4
A second division reached the same entire-suit-only construction of Chapter 25A within days of the first, holding that an action commences at the original petition's filing and that the statute does not permit removing individual claims out of an otherwise-ineligible suit.
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No. 3
Primexx Energy Opportunity Fund v. Primexx Energy Corporation · 2025 Tex. Bus. 9
Granted partial summary judgment holding the general partner met its modified fiduciary duties in connection with the Callon sale, while denying judgment on the proceeds-allocation and waterfall-distribution claims, which proceeded to further litigation.
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No. 4
Primexx Energy Opportunity Fund v. Primexx Energy Corporation (Acconcia and Blackstone Inc. special appearances) · 2025 Tex. Bus. 26
In the same underlying dispute, the court granted the special appearances of Acconcia and Blackstone Inc., dismissing claims against both for lack of personal jurisdiction. A rare Business Court personal-jurisdiction win for the moving parties, and the sharpest data point the docket has produced yet on how the court actually applies the minimum-contacts standard.
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No. 5
Black Mountain SWD v. NGL Water Solutions Permian · 2025 Tex. Bus. 24
Court granted the plaintiff's motion to remand a produced-water dispute, holding the pleaded amount in controversy did not clear the $10 million jurisdictional threshold then in effect. One of the small number of 2025 opinions arising from an energy-sector dispute, and the anchor case for the firm's own computed finding that roughly one in ten coded 2025 Business Court opinions touches the energy sector by name.
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No. 6
Owl AssetCo I v. EOG Resources (first remand) · 2025 Tex. Bus. 30
Court granted remand, holding the amount in controversy did not reach the then-applicable $10 million threshold and that House Bill 40's jurisdictional expansion, not yet effective, did not apply retroactively to a pending motion.
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No. 7
Owl AssetCo I v. EOG Resources (second removal, remand denied) · 2025 Tex. Bus. 47
The same parties returned four months later. After House Bill 40 took effect September 1, 2025 and lowered the general jurisdictional threshold to $5 million, the defendant removed a second time. The court denied the plaintiff's second remand motion, holding the post-H.B.-40 removal was timely and proper under the reduced threshold. Read together, the two Owl AssetCo opinions are the clearest before-and-after pair the 2025 docket produced on House Bill 40's practical effect.
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No. 8
Marathon Oil v. Mercuria Energy America · 2025 Tex. Bus. 39
Resolving four cross-motions for partial summary judgment, the court ruled that the contract's force-majeure and reasonable-efforts provisions did not obligate Marathon to buy spot-market replacement gas or execute a contract buyback during the February 2021 delivery shortfall caused by Winter Storm Uri. A merits-stage contract-interpretation ruling, not a jurisdictional one, on facts that trace back to the storm that did more than any single event to put Texas energy-contract disputes in front of state courts in the first place.
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No. 9
Cadence McShane Construction Co. v. Ryan BB Blockhouse Creek · 2025 Tex. Bus. 43
Denied the plea to the jurisdiction, holding that third-party claims against subcontractors arose from a qualified transaction meeting the $5 million threshold even though the claims themselves were not the original basis for removal. A construction-dispute opinion that reads as a template for how the court treats derivative third-party claims riding on an otherwise-qualifying transaction.
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No. 10
Ornelas v. Herrera · 2025 Tex. Bus. 51
Court held that a partial settlement with other defendants did not divest the court of jurisdiction over the remaining claims, deferring a ruling on the remaining defendant's fiduciary-duty status to a later stage. Included here mainly for what it represents: the Fourth Division decided only four coded matters in 2025, and this procedural ruling is the division's clearest 2025 data point.
By the numbers: the five slowest-resolved matters of 2025
A separate list, selected by the computed criterion described above rather than editorial judgment. These are the five 2025 matters that took the longest from motion filing to the court's ruling, among the matters in the coded dataset where both dates are recorded. Two of the five could not be attributed to named parties from the available record; rather than invent a case name, they are shown by citation number only.
| Matter | Citation | Division | Days, motion to ruling | Disposition |
|---|---|---|---|---|
| City Choice Group v. TMC Grand Blvd Land Co. | 2025 Tex. Bus. 45 | 11th | 284 days | granted in part |
| Slant Operating v. Octane Energy Operating | 2025 Tex. Bus. 53 | 8th | 278 days | granted |
| Kassam v. Dosani | 2025 Tex. Bus. 25 | 11th | 152 days | denied |
| Parties not confirmed for publication source | 2025 Tex. Bus. 8 | 11th | 105 days | granted |
| Parties not confirmed for publication source | 2025 Tex. Bus. 7 | 3d | 104 days | granted |
Computed against the coded dataset as of August 2026. Reproducible: rerun the query against an updated dataset and the ranking may change as more 2025 opinions are located and coded.
Method, and where I am not certain
Before concluding that no other Texas publication runs a review in this exact format, I looked at what else exists. Texas Lawbook publishes an operational retrospective piece and a broader "Top 10 Legal News" year-end roundup that gives the Business Court one paragraph; neither states selection criteria or a case-by-case narrative. Vinson & Elkins and Texas Lawbook jointly publish a recurring quarterly digest, useful but not an annual retrospective. Greenberg Traurig's Business Court Watch runs ongoing case-by-case posts with no annual review edition. SMU's Hilltop Docket is a newer, roughly weekly intelligence brief that has not yet run a year-in-review edition. Lloyd Gosselink published a structural year-in-review piece on the court's first year, with one statistic and no case-selection narrative.
Two pieces I attempted to check directly and still could not: Law.com and Texas Lawyer published "A Year in Review: Highlights from the Texas Business Court's Inaugural Year" (September 25, 2025) and "Texas Business Court Marks Year Two with Landmark Bench Trial and Key Decisions" (January 29, 2026). Both titles suggest they could be the closest match to this format. I located the exact URLs for both, then tried three separate ways to read them: a direct fetch of each page, a fetch of each page's archived snapshot, and a search for excerpts or a syndicated copy on a secondary site such as JDSupra. All three attempts failed; law.com blocks automated retrieval at the publisher level, the archived snapshots returned an access error, and no syndicated copy of either piece turned up. That is a stronger statement than simply not having checked, but it still falls short of an actual read. Until a person opens both links directly in a browser, I am disclosing the gap rather than asserting a competitive landscape I have not verified. If either piece turns out to run a comparable case-selection narrative, this section will be corrected in the next edition.
- This is a first edition, published outside the January convention I intend to keep going forward. Stated directly above, not buried.
- The computed-five list will shift as more 2025 opinions are located and coded. The underlying dataset has documented gaps in opinion recovery; a matter with a longer time-to-ruling than the current fifth-place entry could surface in a future coding pass.
- Two of the fifteen entries carry party names that could not be independently confirmed. They stay in the review, shown by citation, rather than being dropped or given an invented name.
- The "no comparable format found" conclusion rests on an incomplete competitive check. The two blocked Law.com/Texas Lawyer pieces have not been read; see above.
Take the data
All fifteen entries, exactly as published. Download CSVDownload JSON
Free to use, republish and build on, with attribution, under CC BY 4.0. Last verified August 26, 2026. Corrections to hello@kraus.law.
Charles R. Kraus, First Annual Review: Top Texas Business Court Opinions of 2025 (Kraus Law, August 2026), https://www.kraus.law/texas-business-court-annual-review/2025/.
Common questions
How were these ten opinions selected?
By two disclosed criteria, applied together. The qualitative half asks whether a decision meaningfully changed Business Court practice or provided useful clarity on an issue relevant to Texas corporate and commercial litigation. The computed half is this firm's own methodology: the five matters that took longest from motion to ruling in the coded 2025 dataset, a reproducible number nobody has to take on faith. Neither list claims to be exhaustive.
What is the coded dataset this review draws from?
A firm-maintained, opinion-by-opinion coded record of Texas Business Court opinions, the same dataset behind the Texas Business Court Performance Report. It records citation, division, judge, matter type, disposition, and, where the opinion recites both dates, the days elapsed from motion to ruling. Fifty-five of the 123 opinions coded as of this edition were decided in calendar 2025.
Why do two entries omit the parties' names?
2025 Tex. Bus. 7 and 2025 Tex. Bus. 8 are included in the computed by-the-numbers list because they are two of the five slowest-resolved 2025 matters, a fact independent of case name. The official opinion text for one could not be retrieved in machine-readable form and was coded from a secondary source; the other's opinion does not recite the parties in a form this page is willing to publish without independent confirmation. Both are shown by citation rather than an invented case name.
Is this the only year-in-review covering the Texas Business Court?
As of this edition, no other published source appears to run a curated, criteria-disclosed list of opinions in this specific format for the Texas Business Court; the closest published material found is operational retrospective journalism and recurring quarterly digests, not a case-selection narrative. Two Texas Lawyer pieces with titles suggesting a closer match were tracked down by URL and attempted three ways (direct fetch, archived-snapshot fetch, and a search for a syndicated copy); all three attempts failed, and neither piece has actually been read. This page does not claim to be the only one of its kind, only that none was found and confirmed, and that the two candidates most likely to prove otherwise remain unread pending a manual check.
Why publish the first edition in August rather than January?
The Business Court's coded 2025 docket was substantially complete by mid-2026, and there was no reason to hold a first edition for five months. Going forward, each annual edition is intended to publish in January, covering the prior calendar year, matching the convention used by comparable annual-review publications elsewhere.
Fifteen opinions do not summarize a docket. They are a starting point for a conversation about what actually happened.
This review provides general information about selected Texas Business Court opinions and is not legal advice for your specific situation. Case summaries here are necessarily condensed; consult the full opinion, linked from each entry, before relying on any holding described. Consult an attorney licensed in your jurisdiction before relying on any entry here. Chuck Kraus is licensed in Texas, Minnesota, and Alberta.