City of Dallas v. Michelle Mazzaro

CourtCourt of Appeals of Texas
DecidedNovember 23, 2020
Docket05-20-00103-CV
StatusPublished

This text of City of Dallas v. Michelle Mazzaro (City of Dallas v. Michelle Mazzaro) 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 Dallas v. Michelle Mazzaro, (Tex. Ct. App. 2020).

Opinion

Reverse and Dismiss; Opinion Filed November 23, 2020

In The Court of Appeals Fifth District of Texas at Dallas No. 05-20-00103-CV

CITY OF DALLAS, Appellant V. MICHELLE MAZZARO, Appellee

On Appeal from the 134th Judicial District Court Dallas County, Texas Trial Court Cause No. DC-19-00842

MEMORANDUM OPINION Before Justices Whitehill, Pedersen, III, and Reichek Opinion by Justice Pedersen, III The City of Dallas appeals the trial court’s order denying its plea to the

jurisdiction in Michelle Mazzaro’s suit to recover damages for injuries suffered

when she fell while walking on City-owned property.1 The City contends that it is

immune from Mazzaro’s suit because Mazzaro did not timely serve it with the

statutorily required notice of her claims and Mazzaro did not prove that the City had

actual notice of her claims. The City also contends there is no waiver of immunity

for Mazzaro’s premise liability and general negligence claims. We reverse the trial

1 See TEX. CIV. PRAC. & REM. CODE ANN. § 51.014(a)(8) (authorizing appeal of interlocutory order denying governmental unit’s plea to the jurisdiction). court’s order and render judgment dismissing Mazzaro’s suit for lack of subject-

matter jurisdiction.

Background

According to her petition, on January 16, 2017, Mazzaro was walking along

a pathway at the Grassy Knoll in Dealey Plaza when she tripped and fell, injuring

her ankle. Dallas Fire & Rescue paramedics responded to a 9-1-1 call and transported

Mazzaro to the hospital.

On July 14, 2017, Mazzaro sent the City a notice of claim letter apprising it

of her negligence claims against the City. The letter stated that Mazzaro’s fall was

caused by the defective condition of the Monument steps.2 On January 17, 2019,

Mazzaro filed suit against the City alleging that an uneven pathway—not defective

steps—caused her fall and injuries. Mazzaro alleged that the City permitted a

dangerous condition to exist at its premises—the uneven pathway—that posed an

unreasonable risk of harm and proximately caused her injuries. She alleged that the

City knew, or reasonably should have known, about this dangerous condition. She

alleged that the City had duties to inspect and to warn or cure, but it breached those

duties by choosing not to repair the unsafe condition of the uneven pathway on its

premises. She also urged that the City was negligent in hiring, training, and

2 The letter asserted a variety of deficiencies with the steps: improper riser heights and tread widths; improper nosings, handrails, gripping surfaces, and lighting; no proper warning signs; and unsafe condition. –2– supervising employees who caused or failed to repair the unreasonably dangerous

condition.

The City filed a plea to the jurisdiction. The City asserted it was immune from

suit because Mazzaro failed to provide the City with written notice of her claims

within six months of the date of the incident and such failure deprived the trial court

of subject-matter jurisdiction. See TEX. CIV. PRAC. & REM. CODE ANN. § 101.101(a).

The City also asserted it did not have actual notice of Mazzaro’s injury claims. With

respect to Mazzaro’s premise liability claims, the City urged there was no waiver of

immunity under the Texas Tort Claims Act (“TTCA”). The City explained that

Mazzaro had not, and could not, establish a waiver of immunity because the City did

not have prior actual knowledge of the allegedly dangerous condition at the location

of Mazzaro’s fall. Finally, the City argued that Mazzaro was limited to a premise

defect theory of recovery under TTCA and could not show that her claims for

negligence establish a waiver of immunity under TTCA.

In response, Mazzaro argued that the City had timely, actual notice of her

claims. See CIV. PRAC. & REM. § 101.101(c) (stating that TTCA’s notice

requirements do not apply if the governmental entity has actual notice that claimant

has received some injury). She asserted her statement to paramedics that her injury

was caused by a drop off between the bottom step of the Monument and the grass

constituted actual notice to the City. She further asserted that the City is not entitled

to immunity because the City (i) knew it had a duty to maintain level pathways for

–3– its park patrons, (ii) undertook the maintenance of such pathways, thus exhibiting its

knowledge of the risk of uneven pathways, and (iii) failed to properly maintain the

pathways to keep them level. She also urged that the City knew or should have

known about the erosion that caused the drop off from the bottom of the steps to the

ground because such erosion takes place over time. Mazzaro also argued that it could

be inferred that the City had actual knowledge of this defect.

After two hearings, the trial court signed an order denying the City’s plea to

the jurisdiction. The City now appeals that order.

Discussion

In its first issue, the City asserts generally that the trial court erred in denying

the City’s plea to the jurisdiction. In its second, third, and fourth issues, the City

presents three specific arguments to support its assertion that the trial court’s

decision was erroneous.

A. Plea to the Jurisdiction

A plea to the jurisdiction challenges a trial court’s subject-matter jurisdiction.

Texas Dep’t of Transp. v. Jones, 8 S.W.3d 636, 638 (Tex. 1999) (per curiam).

Whether a court has subject matter jurisdiction is a question of law that we review

de novo. Texas Dep’t of Parks & Wildlife v. Miranda, 133 S.W.3d 217, 226 (Tex.

2004). If the evidence creates a fact question regarding jurisdiction, the trial court

cannot grant the plea, and the fact question will be resolved by the factfinder. Id. at

–4– 227–28. However, if the relevant evidence is undisputed or fails to raise a fact issue,

the trial court rules on the plea as a matter of law. Id. at 228.

Under the common law, municipalities like the City of Dallas are immune

from suit and liability for money damages unless the legislature has clearly and

unambiguously waived immunity. Worsdale v. City of Killeen, 578 S.W.3d 57, 62

(Tex. 2019). Absent a valid statutory waiver of immunity, a trial court may not

assume subject-matter jurisdiction over a suit against a governmental unit. City of

San Antonio v. Tenorio, 543 S.W.3d 772, 775 (Tex. 2018) (citing Ryder Integrated

Logistics, Inc. v. Fayette Cty., 453 S.W.3d 922, 926–27 (Tex. 2015)).

B. The Texas Tort Claims Act

The TTCA waives the City’s governmental immunity in certain limited

circumstances, including for personal injury caused by a condition or use of personal

or real property. CIV. PRAC. & REM. § 101.021(2) (providing for waiver of immunity

for personal injury or death caused by condition or use of tangible personal or real

property); see Tenorio, 543 S.W.3d at 775. However, this limited waiver is available

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Related

Texas Department of Parks & Wildlife v. Miranda
133 S.W.3d 217 (Texas Supreme Court, 2004)
City of Dallas v. Carbajal
324 S.W.3d 537 (Texas Supreme Court, 2010)
Cathey v. Booth
900 S.W.2d 339 (Texas Supreme Court, 1995)
Texas Department of Transportation v. Jones
8 S.W.3d 636 (Texas Supreme Court, 1999)
Ryder Integrated Logistics, Inc. v. Fayette County, Texas
453 S.W.3d 922 (Texas Supreme Court, 2015)
City of San Antonio v. Tenorio ex rel. Tenorio
543 S.W.3d 772 (Texas Supreme Court, 2018)

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