City of Corpus Christi v. Gina Rios and Ysabel Martinez, as Next Friend to E.M.

CourtCourt of Appeals of Texas
DecidedNovember 16, 2023
Docket13-21-00414-CV
StatusPublished

This text of City of Corpus Christi v. Gina Rios and Ysabel Martinez, as Next Friend to E.M. (City of Corpus Christi v. Gina Rios and Ysabel Martinez, as Next Friend to E.M.) 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 Corpus Christi v. Gina Rios and Ysabel Martinez, as Next Friend to E.M., (Tex. Ct. App. 2023).

Opinion

NUMBER 13-21-00414-CV

COURT OF APPEALS

THIRTEENTH DISTRICT OF TEXAS

CORPUS CHRISTI – EDINBURG

CITY OF CORPUS CHRISTI, Appellant,

v.

GINA RIOS AND YSABEL MARTINEZ, AS NEXT FRIEND TO E.M., Appellees.

On appeal from the County Court at Law No. 4 of Nueces County, Texas.

MEMORANDUM OPINION

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

Appellees Gina Rios and Ysabel Martinez as next friend to E.M. filed a negligence

suit against appellant the City of Corpus Christi (City) relating to a traffic accident involving a stolen Corpus Christi Police Department (CCPD) vehicle. The City filed a plea to the

jurisdiction arguing that it was protected by governmental immunity from appellees’ suit,

which the trial court denied. In three issues, the City argues that its immunity was not

waived because: (1) appellees’ claims did not arise from the City’s operation or use of a

motor vehicle as required for a waiver under the Texas Tort Claims Act (TTCA), see TEX.

CIV. PRAC. & REM. CODE ANN. § 101.021(1); (2) the City’s officers were entitled to official

immunity; and (3) appellees did not assert a valid waiver of immunity for their claims that

the City’s officers failed to properly handcuff and supervise the arrestee who

commandeered the CCPD vehicle. We reverse and render.

I. BACKGROUND 1

CCPD Officer Armando Vasquez responded to a report of a theft in progress at a

CVS pharmacy in Corpus Christi, Texas. CCPD officers arrested the suspect, later

identified as Alonso Sandoval III, after he fled the store on foot. Officer Vasquez

handcuffed Sandoval with his hands behind his back, placed him in the backseat of his

patrol vehicle, and restrained him with a seat belt. As Officer Vasquez was standing

outside of the vehicle talking to another officer, Sandoval removed his seatbelt and slid

his cuffed hands from behind his back, underneath his feet, to the front of his body. 2

Officer Vasquez then reentered the vehicle and drove back to CVS to finish his

investigation. Officer Vasquez did not see that Sandoval was now unbuckled with his

cuffed hands in the front of his body. Upon his arrival at CVS, Officer Vasquez instructed

fellow officer Graciela Luna-Garcia to monitor Sandoval while he was inside the store.

1 The following facts are derived from the jurisdictional record. The facts are undisputed, except

where otherwise noted.

2 These events were captured on the vehicle’s in-car camera.

2 Officer Vasquez left his key in the ignition so that the air conditioner would continue to run

while Sandoval was in the back seat. The patrol vehicle’s rear doors could not be opened

from the inside, and a plexiglass divider was located between the front and rear seats.

As requested, Officer Luna-Garcia monitored Sandoval from her nearby patrol

vehicle, which was parked directly behind Officer Vasquez’s unit. A short time later,

Officer Luna-Garcia observed Sandoval moving around the back seat area. She

approached the vehicle, opened the front driver side door, and saw that Sandoval had

kicked out the plexiglass divider and was trying to access the front seat. Officer Luna-

Garcia radioed for help while attempting to push Sandoval back into the rear seat.

However, Sandoval overpowered her and gained access to the driver seat. Sandoval

kicked Officer Luna-Garcia away from the vehicle and drove away. Sandoval disregarded

a red light at a nearby intersection and collided with appellees’ vehicle, causing appellees

to suffer personal injuries.

Appellees filed suit against the City alleging that their injuries were due to the

CCPD officers’ negligence. Appellees alleged that the City’s governmental immunity from

suit was waived by the TTCA because their injuries arose from the operation or use of a

motor-driven vehicle. See id. The City answered the suit and filed a plea to the jurisdiction.

In the plea, the City argued that the trial court lacked subject-matter jurisdiction because

no waiver of immunity applied. Specifically, the City argued that the officers’ use of the

vehicle as a holding cell did not constitute the operation or use of a motor vehicle as

contemplated by the TTCA. The City further maintained that there was no causal nexus

between the officers’ alleged negligent use of the vehicle and appellees’ injuries because

Sandoval’s theft of the vehicle was not foreseeable, nor was it the actual cause of the

3 resulting accident. Finally, the City argued that it was immune from vicarious liability for

the officers’ actions because they were protected by official immunity. See City of San

Antonio v. Riojas, 640 S.W.3d 534, 537 (Tex. 2022) (“If [an] employee is protected from

liability by official immunity, the employee is not personally liable to the claimant and the

government retains its sovereign immunity under [Section 101.021(1)].” (quoting DeWitt

v. Harris County, 904 S.W.2d 650, 653 (Tex. 1995) (alterations in original))).

The City attached the following pertinent evidence to its plea: (1) CCPD Officers

Vasquez and Luna-Garcia’s depositions; (2) CCPD Officers George Alvarez, Richard

Olden, and Donald Moore’s affidavits; and (3) Albert Rodriguez’s expert opinion report.

The City argued that the testimony of the CCPD officers and Rodriguez’s expert report

established each element of the official immunity defense. See id. at 537–38 (“Official

immunity is an affirmative defense that inures to all governmental employees who perform

discretionary functions in good faith and within their authority.” (cleaned up)). In his report,

Rodriguez, an expert in law enforcement training, stated that the plexiglass barrier in

Officer Vasquez’s patrol vehicle was designed to keep a detainee contained in the back

seat. Rodriguez further explained that the vehicle’s rear passenger doors could not be

opened from inside the vehicle. He stated that the back seat was equipped with a seat

and shoulder belt system to secure the detainee. Rodriguez opined that, in responding to

a report of theft and arresting the suspect, Officers Vasquez and Luna-Garcia were acting

“within the parameters of the duties and responsibilities law enforcement officers are

assigned to perform.”

Rodriguez explained that Officer Vasquez was performing discretionary functions

in securing, transporting, and monitoring Sandoval. Specifically, Rodriguez stated that

4 “[w]hen and how often to monitor a detainee in the back seat, while in transport, is a

discretionary law enforcement function” and that “[a]ny reasonable and well-trained law

enforcement officer could have reasonably believed Sandoval was adequately secured.”

Rodriguez opined that “[a]ny reasonable law enforcement officer could have believed that

there was no special need to continuously monitor Sandoval, versus checking vehicular

and pedestrian traffic while driving.” Rodriguez emphasized that “the rear seat . . . is

specifically designed to secure detainees with the special[ly] designed seat belts” and

“doors [that] cannot be opened from the inside.” Rodriguez explained that “[i]t is a

common practice for officers to leave patrol units running for the purposes of providing

detainees with appropriate environmental temperatures” and that “[a]ny prudent law

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City of Corpus Christi v. Gina Rios and Ysabel Martinez, as Next Friend to E.M., Counsel Stack Legal Research, https://law.counselstack.com/opinion/city-of-corpus-christi-v-gina-rios-and-ysabel-martinez-as-next-friend-to-texapp-2023.