Bridget Fowler and Phil Fowler v. Tyler Independent School District

CourtCourt of Appeals of Texas
DecidedAugust 15, 2007
Docket12-07-00085-CV
StatusPublished

This text of Bridget Fowler and Phil Fowler v. Tyler Independent School District (Bridget Fowler and Phil Fowler v. Tyler Independent School District) 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
Bridget Fowler and Phil Fowler v. Tyler Independent School District, (Tex. Ct. App. 2007).

Opinion

                                                                                                        NO. 12-07-00085-CV

IN THE COURT OF APPEALS

TWELFTH COURT OF APPEALS DISTRICT

TYLER, TEXAS

BRIDGET FOWLER            §                      APPEAL FROM THE SEVENTH

AND PHIL FOWLER,

APPELLANTS

V.        §                      JUDICIAL DISTRICT COURT OF

TYLER INDEPENDENT

SCHOOL DISTRICT,

APPELLEE   §                      SMITH COUNTY, TEXAS

OPINION

            Bridget and Phil Fowler appeal the trial court’s dismissal of their premises liability lawsuit against the Tyler Independent School District (TISD) for want of jurisdiction based upon TISD’s sovereign immunity from suit.  In their sole issue, the Fowlers assert that, at the time of the injury forming the basis of their lawsuit, TISD was not immune from suit.  We affirm.

Background

            On December 5, 2003, the Fowlers were attendees as spectators at a high school football playoff game between Gilmer High School and Atlanta High School, two public schools within the State of Texas.  TISD, a public school district and governmental unit of the State of Texas, provided the venue for this event, renting their football stadium, Trinity Mother Frances Rose Stadium, to the two schools.  During that event, Bridget Fowler slipped and fell, breaking her leg.


            On December 1, 2005, almost two years after the incident in question, the Fowlers filed suit against TISD alleging that the stadium was in an unreasonably dangerous condition at the time of the football game and that TISD had failed to properly inspect and maintain the stadium and to provide adequate warnings of the stadium’s unsafe condition.  On January 5, 2006, TISD filed its original answer.  On October 3, 2006, TISD filed a plea to the jurisdiction, alleging sovereign immunity from suit.  The trial court granted TISD’s plea.  This appeal followed.

Proprietary Capacity

            In their sole issue, the Fowlers allege that, at the time of Bridget Fowler’s injury, TISD was not immune from suit.

Standard of Review

            Sovereign immunity from suit defeats a trial court’s subject matter jurisdiction. Tex. Dep’t of Transp. v. Jones, 8 S.W.3d 636, 639 (Tex. 1999).  Subject matter jurisdiction is essential to the authority of a trial court to decide a case. Tex. Ass’n of Bus. v. Tex. Air Control Bd., 852 S.W.2d 440, 443 (Tex. 1993).  A plea to the jurisdiction challenges the trial court’s authority to determine the subject matter of a specific cause of action. Starkey ex rel. Ragsdale v. Andrews Ctr., 104 S.W.3d 626, 628 (Tex. App.–Tyler 2003, no pet.).  If a party believes that the plaintiff’s petition does not show jurisdiction and cannot be amended to allege jurisdiction, the party may file a plea to the jurisdiction at any time.  Id. 

            Because subject matter jurisdiction presents a question of law, we review the trial court’s decision to grant a plea to the jurisdiction de novo. Mayhew v. Town of Sunnyvale, 964 S.W.2d 922, 928 (Tex. 1998).  In reviewing a plea to the jurisdiction, we review the pleadings and any evidence relevant to the jurisdictional issue. Tex. Dep’t of Criminal Justice v. Miller, 51 S.W.3d 583, 587 (Tex. 2001). Standing, which is a component of subject matter jurisdiction, requires the pleader to allege facts that affirmatively demonstrate the trial court’s jurisdiction to hear the case.  See Tex. Ass’n of Bus., 852 S.W.2d at 446.

Discussion

            Because it is a governmental unit, a school district is immune from suit under the doctrine of sovereign immunity. See LeLeaux v. Hamshire-Fannett Indep. Sch. Dist., 835 S.W.2d 49, 51 (Tex. 1992).  The doctrine of sovereign immunity bars suit against the State unless the State has given consent to be sued.  Mo. Pac. R.R. Co. v. Brownsville Navigation Dist., 453 S.W.2d 812, 814 (Tex. 1970).  Here, the Fowlers do not claim that sovereign immunity from suit has been waived by consent.  Instead, because TISD was renting its stadium to the two high schools, the Fowlers argue that TISD was acting in a proprietary capacity at the time of Bridget Fowler’s injury, and therefore was not protected by sovereign immunity from suit.

            In 1884, the Texas Supreme Court first carved out an exception to sovereign immunity by defining a municipality’s liability in terms of its governmental and proprietary functions. See City of Galveston v. Posnainsky, 62 Tex. 118, 127 (1884).  In that case, the court reasoned as follows:

It would seem that, in so far as municipal corporations . . . exercise powers conferred on them for purposes essentially public–purposes pertaining to the administration of general laws made to enforce the general policy of the state,–they should be deemed agencies of the state, and not subject to be sued for any act or omission occurring while in the exercise of such power . . . ; that, in reference to such matters, they should stand as does sovereignty, whose agents they are, subject to be sued only when the state, by statute, declares they may be.

                                . . . .

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Related

Texas Ass'n of Business v. Texas Air Control Board
852 S.W.2d 440 (Texas Supreme Court, 1993)
Dillard v. Austin Independent School District
806 S.W.2d 589 (Court of Appeals of Texas, 1991)
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51 S.W.3d 583 (Texas Supreme Court, 2001)
Starkey v. Andrews Center
104 S.W.3d 626 (Court of Appeals of Texas, 2003)
Leleaux v. Hamshire-Fannett Independent School District
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667 S.W.2d 275 (Court of Appeals of Texas, 1984)
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8 S.W.3d 636 (Texas Supreme Court, 1999)
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City of Galveston v. Posnainsky
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