City of Houston v. Varun Lal

CourtCourt of Appeals of Texas
DecidedFebruary 27, 2020
Docket01-19-00625-CV
StatusPublished

This text of City of Houston v. Varun Lal (City of Houston v. Varun Lal) 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 Houston v. Varun Lal, (Tex. Ct. App. 2020).

Opinion

Opinion issued February 27, 2020

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-19-00625-CV ——————————— CITY OF HOUSTON, Appellant V. VARUN LAL, Appellee

On Appeal from the 215th District Court Harris County, Texas Trial Court Case No. 2018-44527

O P I N I O N

The City of Houston appeals from an order denying its plea to the jurisdiction

based on governmental immunity from suit. We affirm the trial court’s order. BACKGROUND

This suit arises out of an auto accident. M. Ryans, a peace officer with the

Houston Police Department, was returning home at night in his City-issued motor

vehicle when he veered into oncoming traffic and struck Varun Lal’s vehicle head-

on. Ryans was off duty on the day of the accident; however, like other officers in the

Department’s vice division, he remained on call to respond to human-trafficking

cases. Just before the accident, Ryans’s City-issued cellular phone rang. Ryans

looked over to pick up his phone to see who was calling him. His momentary

distraction precipitated the accident.

Lal sued the City for negligence. He alleged that the City had waived its

governmental immunity from suit because Ryans was acting within the scope of his

employment as a City employee at the time of the accident.

The City filed a plea to the jurisdiction. It argued that the evidence showed

that Ryans was not acting within the scope of his employment at the time of the

accident and that the City thus had not waived its immunity.

The trial court denied the City’s jurisdictional plea without stating the basis

for its ruling. The City appeals.

DISCUSSION

It is undisputed that municipalities like the City have governmental immunity

from suit except to the extent that it is waived by the Tort Claims Act and that the

2 Act waives this immunity from suit for certain negligent acts by governmental

employees. The City contends that Lal’s suit does not come within the Act’s limited

waiver of immunity because the undisputed evidence conclusively proves that Ryans

was not acting within the scope of his employment at the time of the accident.

Standard of Review

A plea to the jurisdiction based on governmental immunity challenges the trial

court’s subject-matter jurisdiction. City of Houston v. Downstream Envtl., 444

S.W.3d 24, 31 (Tex. App.—Houston [1st Dist.] 2014, pet. denied). The existence of

subject-matter jurisdiction is a question of law subject to de novo review. Anderson

v. Bessman, 365 S.W.3d 119, 123 (Tex. App.—Houston [1st Dist.] 2011, no pet.).

A plea to the jurisdiction may challenge the sufficiency of the jurisdictional

facts pleaded in the petition or the existence of jurisdictional facts. City of Houston

v. Nicolai, 539 S.W.3d 378, 385 (Tex. App.—Houston [1st Dist.] 2017, pet. denied).

The City’s motion challenges the existence of a jurisdictional fact, namely, whether

Ryans was acting within the scope of his employment when the accident happened.

When, as here, a plea to the jurisdiction challenges the existence of

jurisdictional facts, we consider the evidence material to the jurisdictional issues

raised by the parties. Lenoir v. U.T. Physicians, 491 S.W.3d 68, 76 (Tex. App.—

Houston [1st Dist.] 2016, pet. denied). If the evidence is conclusive or does not raise

a fact question as to the jurisdictional issue, then we decide the jurisdictional issue

3 as a matter of law. Id. Conclusive evidence includes undisputed evidence that solely

permits one logical conclusion, evidence that is admittedly true, and evidence that is

conclusively disproved. Id. If, however, the evidence instead raises a fact question

as to the jurisdictional issue, then the plea must be denied and a factfinder must

resolve the issue. Nicolai, 539 S.W.3d at 386; Lenoir, 491 S.W.3d at 76.

The standard of review governing pleas that challenge the existence of

jurisdictional facts thus essentially mirrors the one for summary judgment. Lenoir,

491 S.W.3d at 76. Under this standard, the City bears the burden of proof to present

conclusive evidence that the trial court lacks jurisdiction; if it carries its burden, then

Lal must present evidence sufficient to raise a fact issue. Nicolai, 539 S.W.3d at 386.

We must accept as true all evidence favorable to Lal, indulging every reasonable

inference and resolving any doubts in his favor. Lenoir, 491 S.W.3d at 76–77.

Applicable Law

The Tort Claims Act waives a governmental unit’s immunity from suit for

personal injuries arising from the negligent use of a motor vehicle by an employee

acting within the scope of his employment when the employee would be personally

liable to the claimant under Texas law. TEX. CIV. PRAC. & REM. CODE § 101.021(1).

The City of Houston is a governmental unit for purposes of the Act. Id.

§ 101.001(3)(B); Nicolai, 539 S.W.3d at 386. Under the Act, “scope of employment”

means the performance of “the duties of an employee’s office or employment and

4 includes being in or about the performance of a task lawfully assigned to an

employee by competent authority.” TEX. CIV. PRAC. & REM. CODE § 101.001(5).

Whether a peace officer was on duty or off is not dispositive as to whether he

was acting within his employment’s scope. Garza v. Harrison, 574 S.W.3d 389, 405

(Tex. 2019). Nor is the officer’s use of a police vehicle dispositive. Id. Instead, we

must examine the capacity in which the officer was acting at the time he committed

the allegedly tortious act. Kraidieh v. Nudelman, No. 01-15-01001-CV, 2016 WL

6277409, at *5 (Tex. App.—Houston [1st Dist.] Oct. 27, 2016, no pet.) (mem. op.);

Harris Cty. v. Gibbons, 150 S.W.3d 877, 882 (Tex. App.—Houston [14th Dist.]

2004, no pet.). In simpler terms, we consider what the officer was doing and why he

was doing it. Lara v. City of Hempstead, No. 01-15-00987-CV, 2016 WL 3964794,

at *4 (Tex. App.—Houston [1st Dist.] July 21, 2016, pet. denied) (mem. op.).

In general, an officer acts within the scope of his employment when his act

furthers his employer’s business and is undertaken to accomplish an objective for

which he is employed. Id. at *3. Thus, the mere fact that an off-duty officer was on

call does not render his act within his employment’s scope. City of Balch Springs v.

Austin, 315 S.W.3d 219, 225 (Tex. App.—Dallas 2010, no pet.). On the other hand,

mixed motives do not prevent an officer’s act from being within his employment’s

scope if his act served a purpose of his employer in addition to any other purpose the

act served. Kraidieh, 2016 WL 6277409, at *6. Accordingly, an officer’s act falls

5 outside the scope of his employment if and only if his act did not serve any purpose

of his employer. Garza, 574 S.W.3d at 400–01. The key question in a case like this

one therefore is whether, when viewed objectively, there was a connection between

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Related

Harris County v. Gibbons
150 S.W.3d 877 (Court of Appeals of Texas, 2004)
City of Balch Springs v. Austin
315 S.W.3d 219 (Court of Appeals of Texas, 2010)
City of Houston v. Downstream Environmental, L.L.C.
444 S.W.3d 24 (Court of Appeals of Texas, 2014)
Anderson v. Bessman
365 S.W.3d 119 (Court of Appeals of Texas, 2011)
Lenoir v. U.T. Physicians
491 S.W.3d 68 (Court of Appeals of Texas, 2016)
City of Hous. v. Nicolai
539 S.W.3d 378 (Court of Appeals of Texas, 2017)

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