City of Houston v. Jose Torres

Texas Court of Appeals, 1st District (Houston)·Decided December 31, 2025·No. 01-23-00905-CV·Published

Opinion

Opinion issued December 31, 2025

In The

Court of Appeals

For The

First District of Texas

Background

Jose Torres, a painter employed by Arredondo’s Real Drywall, Inc., was working at Houston Fire Department (HFD) Station #34. When he arrived on the morning of this incident, around 8:30 a.m., there were no emergency vehicles inside the fire station, although some were parked outside.

Torres began setting up his equipment, including a scissor lift, in one of the bays of the fire station so he could paint the station’s ceiling. Because the station’s large bay doors were open, and he needed them closed to paint the ceiling, Torres asked one of the firefighters on duty how to close the doors. Torres closed the bay doors by pushing a red button located inside the station. He then positioned the scissor lift directly behind one of the closed bay doors, elevated himself on it, and began painting the ceiling of the station.

Adam Ricci, a firefighter employed by HFD at Fire Station #34, arrived at the fire station that morning at 6:30 a.m.—two hours before Torres—to begin his 24- hour shift. Around 8:00 a.m.—about 30 minutes before Torres arrived—Ricci left the station in one of the emergency vehicles to respond to a call. Before he left, Ricci did not see anyone painting inside the fire station. And before returning to the station, Ricci had not seen or spoken to Torres and did not know that he (or anyone) was inside the station painting.

When Ricci returned to the fire station, he pushed a remote control inside his vehicle to open one of the bay doors. Unbeknownst to Ricci, Torres was standing on top of the scissor lift directly behind that door. When the door opened, it knocked over the scissor lift, injuring Torres.

The record shows that the bay door could have been deactivated. And, according to the City, District Chief Troy Koteras was the highest-ranking person on site that day—and he had the authority to do that.

Following a bench trial, the trial court found2 that the City “did not act reasonably and its actions proximately causes [Torres’s] injuries.” It concluded that the City was negligent3 and awarded Torres damages.

Governmental Immunity under the Texas Tort Claims Act In three issues,4 the City challenges the trial court’s subject-matter jurisdiction over Torres’s negligence claim. According to the City, the trial court lacked subject-

2 The trial court made this finding in its finding of fact no. 6.

3 Specifically, in conclusion of law no. 8, the trial court concluded: “Defendant City of Houston breached that duty when it activated the mechanically operated bay door while Mr. Torres was painting the interior of the fire department. The City of Houston’s actions proximately caused the accident and the injuries sustained by Mr.

Torres.”

4 The City’s first two issues challenge (1) the trial court’s denial of the City’s motion for judgment because Torres presented no evidence to show that his injuries resulted from conduct that fell within the TTCA’s waiver of immunity and (2) the sufficiency of the evidence to support the trial court’s finding of fact no. 6 and its conclusion of law no. 8. For the reasons discussed below, we address those issues together.

Additionally, because of our disposition of these two issues, we do not reach the

matter jurisdiction because Torres presented no evidence that a City employee breached a legal duty in the operation or use of motor-driven equipment.5 A. Standard of Review Governmental immunity from suit defeats a trial court’s subject-matter jurisdiction. See Tex. Dep’t of Parks & Wildlife v. Miranda, 133 S.W.3d 217, 225– 26 (Tex. 2004); Bland Indep. Sch. Dist. v. Blue, 34 S.W.3d 547, 554 (Tex. 2000). Whether a trial court has subject-matter jurisdiction is ordinarily a question of law, which we review de novo. See Miranda, 133 S.W.3d at 226.

But when, as here, a jurisdictional challenge under the TTCA is raised after a trial on the merits, the standard of review stated in Miranda does not apply. See City of Houston v. Sw. Bell Tel. Co., No. 01-16-00734-CV, 2017 WL 3262131, at *2–3 (Tex. App.—Houston [1st Dist.] Aug. 1, 2017, no pet.) (mem. op.); Prairie View A&M Univ. v. Brooks, 180 S.W.3d 694, 704 (Tex. App.—Houston [14th Dist.] 2005,

City’s third issue—that the trial court erred in awarding Torres an amount of damages above the City’s limit of liability. See TEX. R. APP. P. 47.1.

5 Torres contends that the City’s first two issues are waived. We disagree. As this is an appeal from a bench trial, complaints “regarding the legal or factual insufficiency of the evidence . . . may be made for the first time on appeal in the complaining party’s brief.” See TEX. R. APP. P. 33.1(d). Furthermore, the City raised these same issues, including its immunity, throughout the bench trial, moved for entry of judgment at the close of Torres’s case, and filed a post-trial brief in support of its motion for entry of judgment addressing these issues.

no pet.).6 Instead, when the factfinder’s findings bear on a determination of the trial court’s subject-matter jurisdiction, the appropriate standard of review is whether the evidence is legally sufficient to support the factfinder’s determination of immunity. Sw. Bell Tel. Co., 2017 WL 3262131, at *2.

Additionally, as part of its issues on appeal, the City also challenges the legal and factual sufficiency of the trial court’s determination that it was negligent. When a party appeals from a judgment rendered after a bench trial, the trial court’s findings of fact have the same weight as a jury’s verdict, and we review the sufficiency of the evidence supporting those findings with the same standards that we use to review jury verdicts. See Tex. Outfitters Ltd., LLC v. Nicholson, 572 S.W.3d 647, 653 (Tex. 2019). Because the trial court’s determination of negligence implicates the issue of immunity, Miranda, 133 S.W.3d at 228, we consider the legal sufficiency of the trial court’s determination of the City’s immunity together with the legal and factual sufficiency of its determination of negligence. See Sw. Bell Tel. Co., 2017 WL 3262131, at *3.

Evidence is legally sufficient if it “would enable reasonable and fair-minded people to reach the verdict under review.” City of Keller v. Wilson, 168 S.W.3d 802,

6 Cf. San Antonio Water Sys. v. Nicholas, 461 S.W.3d 131, 136 (Tex. 2015)

(explaining that when jurisdictional challenges under the Texas Commission on Human Rights Act, which waives sovereign immunity for certain claims against governmental entities, are raised after trial on merits, inquiry is whether there is legally sufficient evidence to support jury’s ultimate finding).

827 (Tex. 2005). Evidence is legally insufficient to support a finding if (a) there is a complete absence of evidence of a vital fact, (b) the court is barred by rules of law or evidence from giving weight to the only evidence offered to prove a vital fact, (c) the evidence offered to prove a vital fact is no more than a mere scintilla, or (d) the evidence conclusively establishes the opposite of the vital fact. Id. at 810. When reviewing the legal sufficiency of evidence, we consider the evidence in a light most favorable to the verdict and indulge every reasonable inference to support it. Id. at 822. We also credit favorable evidence if a reasonable juror could and disregard contrary evidence unless a reasonable juror could not. Id. at 827.

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