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Early Knockouts vs. Full Rounds: Comparing Texas Rule 91a and Summary Judgment
By Zeke Moya, Partner at Roerig, Oliveira & Fisher, LLP Introduction: Texas Finally Embraces Early Dismissal Before 2013, Texas civil litigation lacked a mechanism to efficiently dispose of baseless claims early in a case. Motions to dismiss were limited, and parties often had to endure discovery and a full summary judgment process before meritless pleadings could be challenged. Out-of-state clients—accustomed to Federal Rule 12(b)(6)—frequently expressed disbelief. That chan
Zeke Moya
Jan 115 min read


Insurance Defense Attorney Year in Review: A Year of Growth, Gratitude, and Momentum
A year ago, I bet on myself and transitioned to Roerig Oliveira & Fisher, LLP to build my own team and plant a flag. This year stretched my marketing muscles, brought meaningful wins for clients, and reinforced the value of relationships and a team I can count on. Looking ahead to 2026. Ever forward.
Zeke Moya
Dec 24, 20253 min read


Zeke Moya
Nov 17, 20250 min read


Zeke Moya Secures Dismissal for Hospital Client: Appellate Court Confirms Slip-and-Fall Claim Is a Health Care Liability Claim
October 30, 2025 – Thirteenth Court of Appeals Issues Favorable Ruling in Chapter 74 Case Attorney Zeke Moya of Roerig, Oliveira & Fisher, LLP successfully represented a local hospital in both the trial court and on appeal, securing a full dismissal with prejudice in a slip-and-fall lawsuit after the Thirteenth Court of Appeals ruled the claim constituted a Health Care Liability Claim (HCLC) under Texas law. Case Overview The plaintiff, a patient referred for aquatic therapy,
Zeke Moya
Nov 1, 20252 min read


Texas Supreme Court Narrows Scope of Health Care Liability Claims in Leibman v. Waldroup
On June 6, 2025, the Texas Supreme Court issued a 5-4 opinion in Leibman v. Waldroup , No. 23-0317, a closely watched case testing the boundaries of the Texas Medical Liability Act (TMLA). At issue was whether a physician’s conduct—authoring letters for a former patient supporting the need for a service animal—constituted a “health care liability claim” (HCLC) subject to the procedural requirements of Chapter 74 of the Texas Civil Practice and Remedies Code. The Court said no
Zeke Moya
Jun 7, 20253 min read
Clarifying the Limits of Vicarious Liability for Nonprofit Health Organizations in Texas
By Zeke Moya, Trial Counsel for Petitioner in Renaissance Medical Foundation v. Lugo On May 23, 2025, the Texas Supreme Court issued a highly anticipated decision in Renaissance Medical Foundation v. Lugo , addressing whether a nonprofit health organization (NPHO) can be held vicariously liable for the alleged negligence of its employed physician. I had the honor of serving as trial counsel for the petitioner, Renaissance Medical Foundation, in this pivotal case. The Core Leg
Zeke Moya
Jun 1, 20252 min read
SB 30 Moves Forward: From Tort Reform Flashpoint to Complex Procedural Overhaul By Zeke Moya | May 22, 2025
Texas Senate Bill 30 (SB 30) continues to evolve as one of the most closely watched civil justice reform proposals in recent memory....
Zeke Moya
May 22, 20253 min read


HB 4806: The End of Nuclear Verdicts in Texas?
Texas may be on the brink of a significant shift in civil litigation. House Bill 4806 (HB 4806), currently under review by the Judiciary...
Zeke Moya
Mar 14, 20253 min read


SCOTX Considers Scope of Chapter 74 In Case Involving Service Dog Attack: Leibman v. Waldroup
The Texas Supreme Court is reviewing the case of Maurice N. Leibman v. Cleveratta and James Waldroup, Individually and As Next Friends of...
Zeke Moya
Jan 27, 20256 min read


Texas’ Fight Against Nuclear Verdicts: Comparing Two Texas House Bills on Damages in Personal Injury Cases
The Texas Legislature is considering two key bills, House Bill 1419 and House Bill 939, that could significantly impact personal injury...
Zeke Moya
Jan 12, 20253 min read


Defending Premises Liability Lawsuits: Insights from an Insurance Defense Attorney in Texas
As an insurance defense attorney in Texas, defending premises liability lawsuits can be challenging but rewarding work. These cases often...
Zeke Moya
Jan 2, 20253 min read


"Merry Christmas from the Legal Trenches!"
Ah, Christmas! That magical time of year when the air is filled with the aroma of fresh pine trees, gingerbread cookies, and, if you're...
Zeke Moya
Dec 24, 20242 min read


Legislative Update: How Texas’ Proposed Bill Could Reshape Insurance Defense
As insurance professionals, staying ahead of legislative changes is critical to managing claims effectively and protecting your company’s...
Zeke Moya
Dec 21, 20242 min read
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