The Texas Court of Appeals recently ruled in favor of Hacienda Services, Inc., doing business as Censeo Homes, in a case involving a contractor who suffered serious injuries while working on a home. The court's decision, issued on August 31, 2026, is significant as it clarifies the protections provided to property owners under Texas law, particularly in cases involving independent contractors. The ruling affects contractors and property owners alike, as it outlines the conditions under which liability can be established for workplace injuries.
The case, Angel Mendoza v. Hacienda Services, Inc. (docket number 01-24-00620-CV), arose from an incident that occurred on May 10, 2021, when Mendoza was working as a subcontractor for Censeo. Mendoza was engaged in final touch-up work on a one-story house in Angleton, Texas, when he fell from a ladder, resulting in severe injuries, including a traumatic brain injury. Mendoza claimed that Censeo was responsible for his injuries due to negligence and premises liability.
In the dispute, Mendoza argued that Censeo failed to provide a safe workplace and adequate training, and that the company was aware of the dangers associated with the roof where he was working. Censeo, on the other hand, contended that it had no liability under Chapter 95 of the Texas Civil Practice and Remedies Code, which limits the liability of property owners in cases involving independent contractors unless certain conditions are met. The trial court initially ruled in favor of Censeo by granting a take-nothing summary judgment, leading Mendoza to appeal the decision.
In its ruling, the Texas Court of Appeals affirmed the trial court's decision, stating that Censeo had conclusively proven that Chapter 95 applied to Mendoza's claims. The court emphasized that Mendoza had not provided sufficient evidence to demonstrate that Censeo exercised control over the manner in which his work was performed or that the company had actual knowledge of the dangerous condition that caused his injuries. The court noted, "We conclude that the statute applies. In addition, we conclude that Mendoza failed to produce evidence relating to control or actual knowledge in response to Censeo’s no evidence motion for summary judgment."
The ruling clarifies the legal standards under Chapter 95, which protects property owners from liability unless they retain control over the work or have actual knowledge of a dangerous condition. The court highlighted that Mendoza's claims fell under the protections of this statute, as he was an independent contractor performing work on an improvement to real property owned by Censeo.
The court's decision has significant implications for contractors and property owners in Texas. It reinforces the notion that independent contractors bear a substantial responsibility for their safety and the safety of their employees while working on job sites. The ruling may deter future claims against property owners in similar circumstances, as it establishes a clear precedent regarding the application of Chapter 95 in cases involving workplace injuries.
Looking ahead, Mendoza has the option to appeal the decision to the Texas Supreme Court, although it remains uncertain whether he will pursue this route. The case serves as a reminder of the importance of safety measures and the responsibilities of both contractors and property owners in ensuring a safe working environment.
In conclusion, the Texas Court of Appeals' ruling in Angel Mendoza v. Hacienda Services, Inc. underscores the legal protections afforded to property owners under Chapter 95 of the Texas Civil Practice and Remedies Code. The decision not only impacts Mendoza but also sets a precedent for future cases involving independent contractors and workplace injuries in Texas.