American Home Assurance Co. v. Texas Workers' Compensation Commission and Christopher D. Huebner

CourtCourt of Appeals of Texas
DecidedMarch 15, 2001
Docket03-00-00545-CV
StatusPublished

This text of American Home Assurance Co. v. Texas Workers' Compensation Commission and Christopher D. Huebner (American Home Assurance Co. v. Texas Workers' Compensation Commission and Christopher D. Huebner) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
American Home Assurance Co. v. Texas Workers' Compensation Commission and Christopher D. Huebner, (Tex. Ct. App. 2001).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN




NO. 03-00-00545-CV

American Home Assurance Co., Appellant


v.



Texas Workers' Compensation Commission and Christopher D. Huebner, Appellees



FROM THE DISTRICT COURT OF TRAVIS COUNTY, 53RD JUDICIAL DISTRICT

NO. 99-14827, HONORABLE CHARLES F. CAMPBELL, JUDGE PRESIDING

After the State Office of Administrative Hearings ("SOAH") preauthorized treatment to Christopher Huebner in a medical benefits dispute, American Home Assurance Co. ("American") sought judicial review of the administrative order by filing an action against the Texas Workers' Compensation Commission ("the Commission") and Huebner in district court. (1) American appeals from a district court order granting the Commission's plea to the jurisdiction. Tex. Civ. Prac. & Rem. Code Ann. § 51.014(a)(8) (West Supp. 2001). In two issues, American argues that it was entitled to judicial review arising from an inherent right based on due process under the United States and Texas Constitutions (2) and a statutory right, namely, section 2001.171 of the Administrative Procedure Act ("the APA"). Tex. Gov't Code Ann. § 2001.171 (West 2000). We reverse the district court judgment granting the Commission's plea to the jurisdiction.

Factual and Procedural Background

On December 9, 1996, Huebner was exposed to and inhaled vaporized chemicals while on the job. (3) Huebner later developed a medical condition known as chronic inflammatory demyelinating polyneuropathy. Huebner alleges that he discovered his injury on May 23, 1997.

In a matter presently pending in district court, American has contested Huebner's claim of a compensable injury.

The Center for Immune Environmental & Toxic Disorders requested pre-authorization from American to provide Huebner with weekly intravenous gamma globulin treatment for twelve weeks. After American refused to preauthorize such treatments, the Center filed a request with the Medical Review Division of the Commission for medical dispute resolution. The Medical Review Division ordered Huebner to undergo a medical examination with an independent physician who was chosen by the Commission. Because the independent physician disagreed with the Center's recommended course of treatment, the Medical Review Division did not order preauthorization of Huebner's treatments. Huebner appealed the Medical Review Division's decision to SOAH. The administrative law judge reversed the Medical Review Division's decision and ordered preauthorization of the treatments.

Seeking judicial review of this order, American filed suit in district court. The Commission raised its plea to the jurisdiction in its first amended answer, arguing that American had no inherent or statutory right to judicial review. After the supreme court issued its opinion in Continental Casualty Insurance Co. v. Functional Restoration Associates, American amended its petition. 19 S.W.3d 393 (Tex. 2000). The district court granted the Commission's plea to the jurisdiction. American appeals the district court judgment.



Standard of Review

A plea to the jurisdiction challenges the district court's authority to determine the subject matter of the cause of action. Bland Indep. Sch. Dist. v. Blue, 34 S.W.3d 547, 554 (Tex. 2000); City of Austin v. L.S. Ranch, Ltd., 970 S.W.2d 750, 752 (Tex. App.--Austin 1998, no pet.). Subject matter jurisdiction raises a question of law, which we review de novo. See Mayhew v. Town of Sunnyvale, 964 S.W.2d 922, 928 (Tex. 1998).

The plaintiff bears the burden of pleading facts that show the district court has subject matter jurisdiction. Texas Ass'n of Bus. v. Texas Air Control Bd., 852 S.W.2d 440, 446 (Tex. 1993). We examine a plaintiff's good faith factual allegations to determine whether the district court has jurisdiction. See Bland Indep. Sch. Dist., 34 S.W.3d at 554; Brannon v. Pacific Employers Ins. Co., 224 S.W.2d 466, 469 (Tex. 1949). Unless the face of the petition affirmatively demonstrates a lack of jurisdiction, the district court must liberally construe the allegations in the petition in favor of the plaintiff and in favor of jurisdiction. Texas Ass'n of Bus., 852 S.W.2d at 446; Peek v. Equipment Serv. Co., 779 S.W.2d 802, 804 (Tex. 1989). We must therefore determine whether American pleaded facts sufficient to allege that the district court had jurisdiction to review the administrative order.



DISCUSSION

Under Texas law, a plaintiff may seek judicial review of an administrative order in the following three instances: (1) a statute expressly provides for judicial review, (2) the order adversely affects a vested property right, or (3) the order violates some other constitutional right. Continental Cas. Ins. Co., 19 S.W.3d at 397; Stone v. Texas Liquor Control Bd., 417 S.W.2d 385, 385-86 (Tex. 1967).

In its first issue, American argues that it was entitled to judicial review based on its inherent right to due process under the United States and Texas Constitutions. See U.S. Const. amend. XIV, § 1; Tex. Const. art. I, § 19. (4) Specifically, American contends that the administrative order from SOAH requires American to pay for Huebner's treatments. American concludes that, because the order adversely affects its property interest in the monies owed for the preauthorized medical treatments, it has an inherent right to judicial review based on due process.

Relying in part on Chemical Bank & Trust Co. v. Falkner, 369 S.W.2d 427, 433 (Tex. 1963) and Brazosport Savings & Loan Ass'n v. American Savings & Loan Ass'n, 342 S.W.2d 747, 750 (Tex. 1961), this Court has previously stated that when some action by an administrative agency affects a vested property right, the affected party may invoke an inherent right of judicial review. Continental Cas. Ins. Co. v. Functional Restoration Assocs., 964 S.W.2d 776, 779 (Tex. App.--Austin 1998),

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Related

Bland Independent School District v. Blue
34 S.W.3d 547 (Texas Supreme Court, 2000)
City of Austin v. L.S. Ranch, Ltd.
970 S.W.2d 750 (Court of Appeals of Texas, 1998)
Texas Ass'n of Business v. Texas Air Control Board
852 S.W.2d 440 (Texas Supreme Court, 1993)
Texas Workers' Compensation Commission v. Garcia
893 S.W.2d 504 (Texas Supreme Court, 1995)
Chemical Bank & Trust Company v. Falkner
369 S.W.2d 427 (Texas Supreme Court, 1963)
Peek v. Equipment Service Co. of San Antonio
779 S.W.2d 802 (Texas Supreme Court, 1989)
Brazosport Saving & Loan Ass'n v. American Savings & Loan Ass'n
342 S.W.2d 747 (Texas Supreme Court, 1961)
Carrizales v. Texas Department of Protective & Regulatory Services
5 S.W.3d 922 (Court of Appeals of Texas, 1999)
Bybee v. Fireman's Fund Insurance
331 S.W.2d 910 (Texas Supreme Court, 1960)
Continental Casualty Insurance Co. v. Functional Restoration Associates
964 S.W.2d 776 (Court of Appeals of Texas, 1998)
Mayhew v. Town of Sunnyvale
964 S.W.2d 922 (Texas Supreme Court, 1998)
Stone v. Texas Liquor Control Board
417 S.W.2d 385 (Texas Supreme Court, 1967)
University of Texas Medical School at Houston v. Than
901 S.W.2d 926 (Texas Supreme Court, 1995)
National Carloading Corp. v. Phoenix-El Paso Express, Inc.
176 S.W.2d 564 (Texas Supreme Court, 1943)
Brannon v. Pacific Employers Ins. Co.
224 S.W.2d 466 (Texas Supreme Court, 1949)

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American Home Assurance Co. v. Texas Workers' Compensation Commission and Christopher D. Huebner, Counsel Stack Legal Research, https://law.counselstack.com/opinion/american-home-assurance-co-v-texas-workers-compens-texapp-2001.