Justia Government & Administrative Law Opinion Summaries

Houston Police Department Officers Richard Corral and C. Goodman were involved in a high-speed chase of a suspect who had solicited an undercover detective and fled in a stolen vehicle. During the pursuit, Corral's patrol car hit a curb and collided with a pickup truck driven by Ruben Rodriguez and Frederick Okon. Corral claimed the accident occurred because his brakes did not stop him in time. Rodriguez and Okon sued the City of Houston, alleging Corral's negligent driving caused their injuries.The trial court denied the City’s motion for summary judgment, which argued that Corral was protected by official immunity because he acted in good faith and that the emergency exception to the Tort Claims Act applied. The Court of Appeals for the Fourteenth District of Texas affirmed, holding that a fact issue existed regarding whether Corral knew his brakes were not functioning properly, which precluded summary judgment.The Supreme Court of Texas reviewed the case and concluded that Corral acted in good faith as a matter of law. The Court found that Corral's statement about the brakes not working did not reasonably support an inference that he had prior awareness of any defect. The Court emphasized that the summary-judgment evidence showed Corral's brakes were functional but did not stop him in time. The Court also held that the City conclusively established Corral's good faith in making the turn during the pursuit, and the plaintiffs failed to raise a fact issue to controvert this proof.The Supreme Court of Texas reversed the Court of Appeals' judgment and rendered judgment dismissing the case, holding that the City’s governmental immunity was not waived under the Tort Claims Act because Corral was protected by official immunity. View "CITY OF HOUSTON v. RODRIGUEZ" on Justia Law

The Austin American-Statesman requested the University of Texas at Austin to disclose the final results of disciplinary hearings involving sex offenses. The University refused to provide the information without seeking a decision from the Office of the Attorney General (OAG). The Statesman sued the University, seeking a writ of mandamus to compel the disclosure of the records.The trial court granted the Statesman’s motion for summary judgment, ordering the University to produce the requested information. The court found that the University was required to seek an OAG decision and that its failure to do so raised the presumption that the information was subject to disclosure. The court of appeals affirmed the trial court’s decision, holding that the University did not establish a compelling reason for withholding the information and that Section 552.114(b) of the Texas Public Information Act (PIA) did not give the University discretion to withhold the records. The court of appeals also reversed the trial court’s denial of attorney fees to the Statesman.The Supreme Court of Texas reviewed the case and held that Section 552.026 of the PIA grants educational institutions discretion to disclose information in education records if the disclosure is authorized by the Family Educational Rights and Privacy Act (FERPA). The Court concluded that the PIA does not require the release of such information. Additionally, the Court held that the University was not required to seek an OAG decision before withholding the information, as Section 552.114(d) allows educational institutions to redact information without requesting an OAG decision. The Supreme Court of Texas reversed the court of appeals’ judgment and rendered judgment for the University. View "THE UNIVERSITY OF TEXAS AT AUSTIN v. GATEHOUSE MEDIA TEXAS HOLDINGS II, INC." on Justia Law

A fugitive led police on a high-speed chase in Austin, during which Officer Bullock collided with Noel Powell's minivan, causing injuries. Powell, who was not at fault, sued the City of Austin for damages. The City claimed immunity under the Tort Claims Act's emergency exception, which applies if the officer was responding to an emergency and did not act with reckless disregard for safety.The trial court denied the City's plea to the jurisdiction, and the City appealed. The Court of Appeals for the Third District of Texas affirmed, finding a fact issue regarding whether Officer Bullock's actions were reckless, thus requiring further proceedings.The Supreme Court of Texas reviewed the case and held that the officer's conduct did not violate any specific law or ordinance applicable to emergency actions. The court also found that Powell did not raise a fact issue regarding the officer's recklessness. Consequently, the Tort Claims Act did not waive the City's immunity. The Supreme Court of Texas reversed the Court of Appeals' judgment and rendered judgment dismissing the case for lack of jurisdiction. View "THE CITY OF AUSTIN v. POWELL" on Justia Law

A police officer in Buffalo, Texas, was terminated by the City Council after engaging in a high-speed chase with a civilian in his patrol vehicle, resulting in an accident. The officer, Gregory Moliere, received a written reprimand from the Chief of Police, which he accepted. Subsequently, the City Council voted to terminate his employment. Moliere sued, claiming the City Council lacked the authority to fire him and that his due process rights were violated.The trial court dismissed Moliere's suit, finding that the City Council had the authority to terminate him. Moliere appealed, and the Court of Appeals for the Tenth District of Texas reversed the trial court's decision, concluding that there was a fact issue regarding the City Council's authority to terminate Moliere. The appellate court noted ambiguities in the City's employee manual and the police department's policy-and-procedure manual and remanded the case for further proceedings without addressing Moliere's due process claim.The Supreme Court of Texas reviewed the case and determined that the City Council had the authority to terminate Moliere under Texas Local Government Code Section 341.001, which allows the governing body of a Type A general-law municipality to establish and regulate a municipal police force. The court held that the City Council's authority to regulate the police force included the power to terminate officers for cause. Consequently, the Supreme Court of Texas reversed the Court of Appeals' judgment and reinstated the trial court's judgment dismissing Moliere's claims based on the alleged lack of authority to fire him.However, the Supreme Court of Texas remanded the case to the Court of Appeals to address Moliere's due process claim, which had not been considered previously. View "City of Buffalo v. Moliere" on Justia Law

Several homeowners sued an irrigation district, claiming that the district's refusal to remove over twenty-year-old charges from the tax rolls was an ultra vires act, violating the Tax Code's twenty-year limitations period. The district argued that the charges were Water Code assessments, not taxes, and thus not subject to the limitations period.The trial court granted the district officials' jurisdictional plea without permitting discovery, dismissing the homeowners' claims for lack of jurisdiction. The Court of Appeals for the Thirteenth District of Texas affirmed in part, concluding that the pleadings did not support an ultra vires claim under the Tax Code because the homeowners had not sought a refund from the tax assessor and the district had clarified that the charges were assessments under the Water Code.The Supreme Court of Texas reviewed the case and determined that the homeowners had sufficiently pleaded facts to demonstrate the trial court's jurisdiction over their ultra vires claim. The court held that the homeowners' pleadings, viewed liberally, alleged that the charges were taxes, had been delinquent for more than twenty years, and that no related litigation was pending at the time of the request to remove the charges. The court concluded that these allegations were sufficient to establish subject matter jurisdiction and did not implicate the district's governmental immunity.The Supreme Court of Texas reversed the Court of Appeals' judgment regarding the Tax Code ultra vires claim and remanded the case to the trial court for further proceedings consistent with its opinion. View "Herrera v. Mata" on Justia Law

Dallas County sued state officials in Travis County, alleging that the Texas Health and Human Services Commission (HHSC) failed to take custody of criminal defendants adjudicated incompetent to stand trial, imposing costs on the County. The district court denied the State’s plea to the jurisdiction, leading to an appeal in the Third Court of Appeals. However, due to legislative changes, this appeal is set to be transferred to the newly created Fifteenth Court of Appeals, which will have exclusive jurisdiction over certain state-related cases.The Third Court of Appeals could not resolve the appeal before its mandatory transfer to the Fifteenth Court. Dallas County preferred to remain in the Third Court and petitioned the Supreme Court of Texas to bar the transfer and declare the legislation creating the Fifteenth Court unconstitutional. The County argued that the Fifteenth Court’s statewide jurisdiction, its jurisdictional scope, and the appointment process for its justices were unconstitutional.The Supreme Court of Texas reviewed the case and held that it had jurisdiction over Dallas County’s petition. The Court concluded that the creation of the Fifteenth Court was constitutional. It found that the Texas Constitution allows the legislature substantial discretion in creating courts and defining their jurisdiction. The Court also held that the appointment process for the Fifteenth Court’s justices, who will be appointed initially and then elected in the next general election, was constitutional. Consequently, the Court denied Dallas County’s request for relief, meaning the appeal must be transferred to the Fifteenth Court as scheduled. View "IN RE DALLAS COUNTY, TEXAS AND BROWN" on Justia Law

The case involves Dianne Hensley, a justice of the peace in Texas, who announced that due to her religious beliefs, she would not perform weddings for same-sex couples but would refer them to others who would. The State Commission on Judicial Conduct issued her a public warning for casting doubt on her capacity to act impartially due to the person's sexual orientation, in violation of Canon 4A(1) of the Texas Code of Judicial Conduct. Hensley did not appeal this warning to a Special Court of Review (SCR) but instead sued the Commission and its members and officers for violating the Texas Religious Freedom Restoration Act (TRFRA) and her right to freedom of speech under Article I, Section 8 of the Texas Constitution. The trial court dismissed her claims for lack of jurisdiction, and the court of appeals affirmed.The Supreme Court of Texas held that Hensley's suit was not barred by her decision not to appeal the Commission’s Public Warning or by sovereign immunity. The court affirmed the part of the court of appeals’ judgment dismissing one of Hensley's declaratory requests for lack of jurisdiction, reversed the remainder of the judgment, and remanded to the court of appeals to address the remaining issues on appeal. The court found that the SCR could not have finally decided whether Hensley is entitled to the relief sought in this case or awarded the relief TRFRA provides to successful claimants. View "HENSLEY v. STATE COMMISSION ON JUDICIAL CONDUCT" on Justia Law

The case involves Ammonite Oil & Gas Corporation (Ammonite) and the Railroad Commission of Texas and EOG Resources, Inc. (EOG). Ammonite leases mineral rights beneath a riverbed from the State of Texas. EOG leases the minerals on the land adjoining the river on both sides. All the minerals in the area lie in a common subsurface reservoir. EOG's wells, however, do not reach the minerals beneath the riverbed. Ammonite argued that without pooling, its minerals are left stranded. Ammonite applied to the Railroad Commission for forced pooling under the Texas Mineral Interest Pooling Act (MIPA).The Railroad Commission rejected Ammonite's applications to force-pool the minerals beneath the river—which are not being produced—with those beside it—which are. The lower courts affirmed the Commission’s order. The Supreme Court of Texas also affirmed the lower courts' decisions but for different reasons than the court of appeals gave.The Supreme Court of Texas held that the Commission’s conclusion that “Ammonite failed to make a fair and reasonable offer to voluntarily pool as required by [MIPA Section] 102.013” is reasonable. The court also held that Ammonite has failed to show that forced pooling of its acreage with EOG’s wells is necessary to prevent its minerals from ultimately being lost. The court concluded that Ammonite applied for a share of EOG’s revenue without contributing to it and that the Commission’s conclusion that forced pooling would not prevent waste or protect correlative rights is not unreasonable. View "AMMONITE OIL & GAS CORPORATION v. RAILROAD COMMISSION OF TEXAS" on Justia Law

This case involves a dispute over the interpretation of a statute that regulates healthcare providers participating in the federal Medicaid program. The State of Texas, acting through the Attorney General, sought to enforce a statute that imposes penalties on a provider who submits a claim for payment and knowingly fails to indicate the type of professional license and the identification number of the person who actually provided the service. The defendant, a dentist, argued that the statute only applies if a claim fails to indicate both the license type and the identification number of the actual provider.Previously, the trial court granted the State's motion for partial summary judgment and denied the defendant's motion. The court rendered a final judgment awarding the State more than $16,500,000. The defendant appealed, and the court of appeals affirmed the trial court's judgment, except for the amount of attorney’s fees and expenses.The Supreme Court of Texas reversed the lower courts' decisions. The court agreed with the defendant's interpretation of the statute. The court held that the statute applies only if a claim fails to indicate both the license type and the identification number of the actual provider. The court found that the 1,842 claims at issue did indicate the actual providers’ license type, so they did not constitute an unlawful act under the statute. The court rendered judgment in the dentist’s favor. View "MALOUF v. THE STATE OF TEXAS EX RELS. ELLIS AND CASTILLO" on Justia Law

The case involves Image API, LLC, a company that provided services to the Texas Health and Human Services Commission (HHSC) from 2009 to 2015. Image's job was to manage a processing center for incoming mail related to Medicaid and other benefits programs. The agreement between the parties stated that HHSC would compensate Image using its “retrospective cost settlement model”. In 2016, HHSC notified Image that an independent external firm would conduct an audit of Image’s performance and billing for the years 2010 and 2011. The audit concluded that HHSC had overpaid Image approximately $440,000 in costs relating to bonuses, holiday pay, overtime, and other unauthorized labor expenses. HHSC then sought to recoup the overpayments by deducting from payments on Image’s invoices.The trial court granted HHSC’s motion for summary judgment and signed a final judgment for the commissioner. The court of appeals reversed the trial court’s judgment and dismissed Image’s entire suit for want of jurisdiction. Image sought review.The Supreme Court of Texas held that Image is a Medicaid contractor under Section 32.0705(a), and that the deadline in Section 32.0705(d) for auditing HHSC’s Medicaid contractors is mandatory. However, the court ruled that HHSC’s failure to meet the deadline does not preclude it from using the result of the audit or pursuing recoupment of overcharges found in the audit. The court affirmed the part of the court of appeals’ judgment dismissing Image’s claims arising from the 2016 audit for lack of jurisdiction, reversed the part of the judgment dismissing the remainder of Image’s suit, and remanded to the trial court for further proceedings. View "IMAGE API, LLC v. YOUNG" on Justia Law