Justia Texas Supreme Court Opinion Summaries

Articles Posted in Government & Administrative Law
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Petitioners, former employees of the City of Houston, filed suit against the Houston Municipal Employees Pension System (HMEPS) board members, asserting that the board members violated HMEPS’s enabling statute by requiring Petitioners’ continued participation in the City’s defined-benefit pension plan. The trial court found jurisdiction to be lacking, and the court of appeals affirmed. As provided by statute, the pension board has exclusive authority to interpret and supplement omissions in the statute and to determine all questions of law and fact pertaining to eligibility for membership, services and benefits. The board’s actions with respect to these matters are final and binding and therefore not amenable to judicial review. To defeat this jurisdictional bar, Petitioners asserted that subject-matter jurisdiction exists when the pension board fundamentally alters the terms of the statute without the City’s consent. The Supreme Court affirmed, holding that the trial court lacked subject-matter jurisdiction over the claims because (1) the pension board acted within the scope of its authority in construing the term “employee”; and (2) Petitioners failed to assert viable constitutional claims. View "Klumb v. Houston Municipal Employees Pension Sys." on Justia Law

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Invoking the Texas Public Information Act (PIA), Randall Kallinen requested information from the City of Houston regarding a study of traffic light cameras the City had commissioned. The City withheld some documents and asked the Attorney General for an opinion as to whether the PIA excepted the withheld information from disclosure. Before the Attorney General ruled, Kallinen sued for a writ of mandamus to compel the City to disclose the withheld information. The City filed a plea to the jurisdiction, arguing that the court lacked jurisdiction over the suit until the Attorney General ruled. The district court overruled the plea, ordered disclosure of the withheld documents, and awarded Kallinen attorney fees. The court of appeals reversed, holding that a trial court lacked subject matter jurisdiction over this suit until the Attorney General ruled. The Supreme Court reversed, holding that the court of appeals erred in dismissing Kallinen’s suit for want of jurisdiction, as a requestor of information is not required to defer a suit for mandamus while awaiting the Attorney General’s decision. View "Kallinen v. City of Houston" on Justia Law

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Petitioner was court-martialed for sexual abuse and assault and imprisoned for eighteen years. Approximately two decades after the conviction, Petitioner applied to the Texas Department of Licensing and Regulation for a tow truck operator’s license. The Department denied Petitioner’s application based on his conviction. Petitioner contested the denial. An administrative law judge (ALJ) from the State Office of Administrative Hearings recommended that the Department issue a license. The Department, however, revised the ALJ’s findings of fact and conclusions of law to reject Petitioner’s application. The trial court reversed the Department’s decision, concluding that the Department’s alterations of the findings and conclusions were unlawful. The court of appeals reversed, ruling that the Department’s modifications were improper because the ALJ misinterpreted a provision of the Texas Occupations Code concerning licensing restrictions where an applicant has previously been convicted of a crime. The Supreme Court reversed, holding that the Department’s revisions of the findings of fact and conclusions of law constituted error because the revisions were unsupported by the plain language of the statute. View "Thompson v. Tex. Dep’t of Licensing & Reg." on Justia Law

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After the State Board for Educator Certification revoked the teaching certificate of a schoolteacher, the schoolteacher sued to overturn the revocation. The trial court concluded that the Board’s decision was not supported by substantial evidence and was arbitrary and capricious. The court issued a permanent injunction prohibiting the Board from revoking the schoolteacher’s revocation and refused to allow the Board to supersede the judgment pending appeal. The State sought mandamus relief challenging the trial court’s denial of supersedeas. The court of appeals denied mandamus relief and abated the merits of the Board’s appeal pending the Supreme Court resolution of a narrow procedural issue. The Supreme Court denied relief, holding that a trial court has discretion to prevent the Board from re-revoking a teacher’s professional license while the Board appeals the court’s rejection of the Board’s initial revocation. View "In re State Bd. for Educator Certification" on Justia Law

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Respondent, a principal at a school in the Yesleta Independent School District (ISD), reported various "asbestos hazards" in the school to certain school officials. Eventually, the ISD indefinitely suspended Respondent. Respondent filed this whistleblower claim, alleging that the ISD violated the Asbestos Hazard Emergency Response Act (Act) by failing to respond to his asbestos reports. In so claiming, Respondent submitted no evidence showing that the ISD enforced the Act beyond its own internal compliance or that he reported the allegations to anyone other than school officials. The trial court denied the ISD's plea to the jurisdiction, concluding that Respondent produced sufficient evidence of his good faith belief that the ISD's superintendent and trustees were authorized to regulate under or enforce the Act. The court of appeals affirmed. The Supreme Court reversed and granted the plea to the jurisdiction, holding that a report to personnel whose only power is to oversee compliance within the entity itself is not enough to confer "law-enforcement authority" status. View "Ysleta Indep. Sch. Dist. v. Franco" on Justia Law

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Respondent, a firefighter for the Houston Fire Department, suffered an on-the-job injury in 1988. The City of Houston and Respondent entered into a settlement agreement under which Respondent would receive lifetime medical expenses in exchange for releasing the City from any further claims derived from the injury. In 2004, the City stopped paying for many of Respondent's medical expenses, concluding they were not reasonable or necessary. A jury found for Respondent and awarded him $127,500 in damages. The City petitioned for the Supreme Court's review, arguing (1) the trial court lacked jurisdiction to hear the case because Respondent did not exhaust his administrative remedies as required by statute; and (2) governmental immunity shielded the City from suit. The Supreme Court reversed and dismissed Respondent's action for lack of subject matter jurisdiction, holding that Respondent failed to exhaust his administrative remedies as required by statute, and therefore, the trial court was divested of jurisdiction. View "City of Houston v. Rhule" on Justia Law

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This proceeding arose from an application to amend an existing water-quality permit filed by the owner and operator of a dairy farm located in the North Bosque River watershed. The City of Waco and Bosque River Coalition opposed the proposed permit. After the executive director of the Texas Commission on Environmental Quality determined that the application and draft permit met the requirements of applicable law, the Coalition asked to intervene as a party in a contested case hearing. The Commission denied the request, finding that the Commission lacked standing, and issued the permit. The district court affirmed, but the court of appeals reversed, finding that the Coalition was an "affected person" as defined by the Texas Water Code and thus was entitled to a contested case hearing. The Supreme Court reversed, holding that, pursuant to Texas Commission on Environmental Quality v. City of Waco, the companion to this case, the Coalition's status as an affected person was not determinative of the right to a contested case hearing because the Water Code expressly exempted the proposed amendment from contested case procedures. View "Tex. Comm'n on Envtl. Quality v. Bosque River Coalition" on Justia Law

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The Texas Commission on Environmental Quality (Commission) granted an amendment to a dairy concentrated animal feeding operation's water-quality permit. A downstream city (City) sought to intervene in the permit process and obtain a contested case hearing, claiming that the dairy's operations under the amended permit would adversely affect the quality of the municipal water supply. By rule, an affected person may request a contested case hearing when authorized by law. The Commission granted the amended permit without a contested case hearing. The City appealed, claiming it was an "affected person" entitled to a contested case hearing. The district court affirmed, but the court of appeals reversed, concluding that the City was an affected person entitled to a hearing. The Supreme Court reversed and rendered judgment for the Commission, holding (1) a person affected by a proposed water-quality permit has the right to request a hearing, but the Commission has discretion to deny the request under certain circumstances; and (2) sufficient evidence supported the Commission's determination that the proposed amended permit did not foreclose Commission discretion to consider the amended application at a regular meeting rather than after a contested case hearing. View "Tex. Comm'n on Envtl. Quality v. City of Waco" on Justia Law

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A government contractor (HCSC) contracted with the federal government to administer two health insurance programs. HCSC incurred expenses while performing the contracts that were reimbursed by the government. After the Comptroller denied HCSC's request for a refund for some of the sales and use taxes it paid on the expenses, HCSC brought tax-refund suits, claiming the purchases it made to administer the health-insurance programs qualified for the Tax Code's sale-for-resale exemption, which grants purchasers of taxable goods and services a sales-tax exemption if they resell the items. The lower courts determined HCSC was entitled to the claimed refunds. The Supreme Court affirmed on all but one issue, holding (1) the exemption applied to HCSC's requested refunds for tangible personal property and taxable services; but (2) the exemption did not apply to HCSC's requested refunds for leases of tangible of personal property. Remanded. View "Combs v. Health Care Servs. Corp." on Justia Law

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A staffing services company (Company) furnished workers for the City, including Respondent. During the course of his employment, Employee lost an arm working on a garbage truck driven by an employee of the City. Respondent sued the City and its employee (collectively, Petitioners). Petitioners filed a motion for summary judgment, asserting governmental immunity based in part on the exclusive remedy under the Texas Labor Code, which provides that recovery of workers' compensation benefits is the exclusive remedy of an employee covered by workers' compensation insurance. The trial court dismissed the case. The court of appeals reversed, holding that a fact question remained whether Respondent, who was paid by Company, was within the specific terms of the City's workers' compensation coverage. The Supreme Court reversed and dismissed the case, holding that, as a matter of law, the City provided Respondent's workers' compensation coverage, and therefore, Respondent's exclusive remedy was the compensation benefits to which he was entitled. View "City of Bellaire v. Johnson" on Justia Law