TX STATETexas Court of Appeals, 5th District (Dallas)
2015

Blackstone Medical, Inc. D/B/A Orthofix Spinal Implants v. Phoenix Surgicals, LLC

470 S.W.3d 636Texas Court of Appeals, 5th District (Dallas) • Decided 2015Enforced

HOLDING

Orthofix, a medical device supplier, terminated its distribution agreement with Phoenix Surgicals and claimed the contract couldn't be enforced due to the statute of frauds. The Texas Court of Appeals upheld a jury verdict awarding Phoenix over $705,000 for wrongful termination and promissory estoppel. The court found that Orthofix had waived its exclusivity rights through prolonged silence and inaction, making the termination wrongful even though the original contract had issues.

KEY FINDINGS

Termination for Convenience

Silence or inaction on enforcing contract terms can constitute a waiver—don't assume you can enforce strict contract language if you've ignored violations for a long time

Dispute Resolution

Termination-for-convenience clauses may not protect you if you've waived exclusivity or other key provisions through your conduct or past practice

FULL COURT OPINION