Beeman v. Livingston

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Petitioners in this case were deaf inmates housed in a unit of the Texas Department of Criminal Justice (TDCJ). Petitioners sued TDCJ’s executive director, asserting that he violated the Texas Human Resources Code by failing reasonably to accommodate their impairment. Petitioners relied on the ultra vires exception to sovereign immunity as a basis for showing that the trial court had jurisdiction. The trial court granted a temporary injunction ordering TDCJ to make certain accommodations. The court of appeals reversed and dismissed the case for want of jurisdiction, holding that TDCJ prison facilities are not “public facilities” under the Code, and therefore, Defendant could not have acted ultra vires by failing to comply with its provisions. The Supreme Court affirmed, holding that the court of appeals did not err in holding that TDCJ prisons are not “public facilities” under the Code and that Petitioners failed to show Defendant acted ultra vires. View "Beeman v. Livingston" on Justia Law