City of Brownsville v. Evaristo Gamez Jr.

CourtCourt of Appeals of Texas
DecidedJanuary 4, 2024
Docket13-23-00159-CV
StatusPublished

This text of City of Brownsville v. Evaristo Gamez Jr. (City of Brownsville v. Evaristo Gamez Jr.) 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
City of Brownsville v. Evaristo Gamez Jr., (Tex. Ct. App. 2024).

Opinion

NUMBER 13-23-00159-CV

COURT OF APPEALS

THIRTEENTH DISTRICT OF TEXAS

CORPUS CHRISTI – EDINBURG

CITY OF BROWNSVILLE, Appellant,

v.

EVARISTO GAMEZ JR., Appellee.

On appeal from the 444th District Court of Cameron County, Texas.

MEMORANDUM OPINION

Before Chief Justice Contreras and Justices Silva and Peña Memorandum Opinion by Justice Silva

Appellant City of Brownsville (the City) appeals the trial court’s order denying its

plea to the jurisdiction, seeking to have appellee Evaristo Gamez Jr.’s claims for wrongful

termination against it dismissed. By one issue with multiple subparts, the City argues that

the trial court erred by denying its plea to the jurisdiction because Gamez could not

establish that the City’s governmental immunity had been waived. We reverse and render in part, reverse and remand in part, and affirm in part.

I. BACKGROUND

Gamez’s live pleading alleged that he was a City employee for over thirty years,

reaching the position of director of operations for building planning. On November 20,

2017, the City transferred Gamez to the position of director of operations for the animal

shelter. 1 However, on September 30, 2018, Gamez was terminated because, according

to the City, the position was not included in the budget for fiscal year 2019 or beyond.

Gamez’s duties as director of operations for the animal shelter were transferred to the

already existing position of director of public health and wellness. Gamez further

explained that prior to his termination, he was diagnosed with and treated for cancer.

Gamez alleged that the City transferred his position and subsequently terminated

him because of his age and disability and in retaliation for opposing a discriminatory act.

Accordingly, Gamez brought claims for wrongful termination under the Texas

Commission on Human Rights Act (TCHRA), seeking damages for lost wages, past and

future mental anguish, and exemplary damages.

The City filed a plea to the jurisdiction, challenging certain jurisdictional facts.

Specifically, the City asserted that it had a nondiscriminatory reason to terminate Gamez

and that he was not actually disabled for the purposes of the TCHRA. Lastly, the City

argued that Gamez “ha[d] not alleged, and he [could not] show, that he ha[d] opposed a

discriminatory practice” so as to establish a retaliation claim. The City attached seven

1 Gamez alleged that he was first notified of the impending move on June 16, 2017. However, it

was not until he received a notice on October 12, 2017, that the transfer was confirmed. Gamez’s first day as director of operations for the animal shelter was November 20, 2017.

2 exhibits to its plea, including the letter notifying Gamez of the elimination of his position,

Gamez’s retirement paperwork, Gamez’s charge of discrimination filed with the Texas

Workforce Commission (TWC), affidavits from two City employees, and Gamez’s

deposition.

Gamez responded to the City’s plea, arguing, in part, that the City did not establish

facts negating his prima facie case. 2 According to Gamez, the trial court was required to

deny the plea to the jurisdiction because he pleaded a prima facie case for each charge

of discrimination or retaliation. Additionally, Gamez alleged that “[t]he stated reason for

[his] termination—elimination of his position[—]is false, discriminatory[,] and is a

pretextual reason.” Gamez attached an affidavit to his response, wherein he reiterated

his argument, that the City’s stated reason for his termination was pretextual. Gamez also

averred that he “opposed a discriminatory practice when Michael Lopez, Interim City

Manager, transferred [Gamez’s] directorship from [o]perations [m]anager/[b]uilding

[o]fficial to the [a]nimal [s]helter.”

The trial court denied the City’s plea to the jurisdiction. This interlocutory appeal

followed. See TEX. CIV. PRAC. & REM. CODE ANN. § 51.014(a)(5).

II. STANDARD OF REVIEW

“A plea to the jurisdiction is a dilatory plea, the purpose of which is to defeat a

cause of action without regard to whether the claims asserted have merit.” Bland Indep.

Sch. Dist. v. Blue, 34 S.W.3d 547, 554 (Tex. 2000). The plea challenges the trial court’s

2 Gamez casts the City’s plea as “only challeng[ing] and produc[ing] evidence relating to the existence of evidence,” which he contended the City cannot do.

3 subject matter jurisdiction over a pleaded cause of action. Tex. Dep’t of Parks & Wildlife

v. Miranda, 133 S.W.3d 217, 226 (Tex. 2004). “When a plea to the jurisdiction challenges

the pleadings, we determine if the pleader has alleged facts that affirmatively demonstrate

the court’s jurisdiction to hear the cause,” construing “the pleadings liberally in favor of

the plaintiff[] and look to the pleader[’s] intent.” Id.

A plaintiff has the burden to affirmatively demonstrate the trial court’s jurisdiction.

Town of Shady Shores v. Swanson, 590 S.W.3d 544, 550 (Tex. 2019). “When a defendant

challenges jurisdiction, a court ‘is not required to look solely to the pleadings but may

consider evidence and must do so when necessary to resolve the jurisdictional issues

raised.’” Id. (quoting Bland Indep. Sch. Dist., 34 S.W.3d at 555); see Jones v. Turner, 646

S.W.3d 319, 325 (Tex. 2022) (explaining that a plea to the jurisdiction may challenge the

pleadings, the existence of jurisdictional facts, or both). This is true even when the

jurisdictional issue intertwines with the merits of the case. Swanson, 590 S.W.3d at 550.

When jurisdictional facts are challenged, our standard of review mirrors that of a

summary judgment. Alamo Heights Indep. Sch. Dist. v. Clark, 544 S.W.3d 755, 805 (Tex.

2018). We must take as true all evidence favorable to the nonmovant, indulge every

reasonable inference and resolve any doubts in the nonmovant’s favor, and disregard

contrary evidence unless a reasonable factfinder could not. See id. at 771; Miranda, 133

S.W.3d at 228. If the evidence raises a fact issue regarding jurisdiction, the plea cannot

be granted, and a factfinder must resolve the issue. Miranda, 133 S.W.3d at 227–28. On

the other hand, if the evidence is undisputed or fails to raise a fact issue, the plea must

be determined as a matter of law. Mission Consol. Indep. Sch. Dist. v. Garcia, 372 S.W.3d

4 629, 635 (Tex. 2012); Miranda, 133 S.W.3d at 228.

“A genuine issue of material fact exists if more than a scintilla of evidence

establishing the existence of the challenged element is produced.” Ford Motor Co. v.

Ridgway, 135 S.W.3d 598, 600 (Tex. 2004). The evidence must “rise[] to a level that

would enable reasonable and fair-minded people to differ in their conclusions.” First

United Pentecostal Church of Beaumont v. Parker, 514 S.W.3d 214, 220 (Tex. 2017)

(quoting Merrell Dow Pharm., Inc. v. Havner, 953 S.W.2d 706, 711 (Tex. 1997)).

However, a factfinder may not reasonably infer an ultimate fact from meager

circumstantial evidence which could give rise to any number of inferences, none more

probable than another. Kingsaire, Inc.

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