City of Montgomery v. David McCorquodale

CourtCourt of Appeals of Texas
DecidedNovember 6, 2025
Docket09-25-00265-CV
StatusPublished

This text of City of Montgomery v. David McCorquodale (City of Montgomery v. David McCorquodale) 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 Montgomery v. David McCorquodale, (Tex. Ct. App. 2025).

Opinion

In The

Court of Appeals

Ninth District of Texas at Beaumont

__________________

NO. 09-25-00265-CV __________________

CITY OF MONTGOMERY, Appellant

V.

DAVID MCCORQUODALE, Appellee

__________________________________________________________________

On Appeal from the 284th District Court Montgomery County, Texas Trial Cause No. 24-11-18479 __________________________________________________________________

MEMORANDUM OPINION

The City of Montgomery (“the City”) appeals from the trial court’s order

denying the City’s plea to the jurisdiction. David McCorquodale, the City’s former

Assistant City Administrator and Planning/Development Director, filed a wrongful

termination suit against the City, asserting claims under the Texas Whistleblower’s

Act. See Tex. Gov’t Code Ann. §§ 554.001-010 (the “Act”). In one appellate issue,

the City argues the trial court erred in denying its plea because McCorquodale failed

to raise a genuine issue of material fact on whether he initiated a grievance before

1 filing suit as required by the Act. See id. § 554.006. For the reasons explained below,

we conclude that McCorquodale failed to raise a fact question as to whether he

“initiate[d] action under the [City’s] grievance or appeal procedures[.]” Id. §

554.006(a). We reverse the trial court’s order denying the plea to the jurisdiction,

and we render a dismissal of McCorquodale’s claims against the City for lack of

jurisdiction.

Background

On November 25, 2024, McCorquodale filed Plaintiff’s Original Petition

against the City after the City allegedly terminated his employment as Assistant City

Administrator and Planning/Development Director in retaliation for

McCorquodale’s reporting of the police chief’s “trying to pass a fraudulent

employment agreement that contradicted his actual signed hiring documents off as

legitimate in order to obtain more benefits and a higher salary.” According to the

petition, McCorquodale reported that the City’s police chief had engaged in

fraudulent activity. McCorquodale reported the alleged fraud to the City Attorney

and later to the City Administrator, who recommended McCorquodale report it to

the District Attorney’s Public Integrity Section. McCorquodale informed the City

Attorney and the City Administrator that he submitted the alleged fraud to the DA,

and after reporting it, the City’s mayor allegedly verbally attacked McCorquodale,

targeted him during public meetings, and made false accusations against

2 McCorquodale to have him terminated. In McCorquodale’s petition, he alleges that

on November 18, 2024, the City Council voted to immediately terminate him and to

terminate the City Administrator, and they were provided no reason for their

termination. McCorquodale alleges the City intentionally violated the Act by

retaliating against him and terminating his employment for reporting the police

chief’s illegal behavior. McCorquodale seeks monetary damages, including lost

earnings, lost benefits, punitive damages, mental anguish, and attorney’s fees.

The City filed Defendant’s Original Answer, generally denying

McCorquodale’s allegations and asserting the defense of governmental immunity

“except and to the extent this cause of action fits within the Texas Whistleblower

Act, Tex. Gov’t Code Chap[ter] 554.” The City’s Answer alleges that

McCorquodale’s employment was terminated for non-retaliatory reasons “having

nothing to do with his alleged exercise of speech that he claims was protected by the

Texas Whistleblower Act.”

The City filed a Plea to the Jurisdiction, moving to dismiss McCorquodale’s

Whistleblower claim for want of subject-matter jurisdiction because he failed to

“‘initiate [the City’s] grievance or appeal procedures’” required by section 554.006

of the Texas Government Code. According to the City, McCorquodale was required

by section 6.16 of the City’s Policies & Procedures Manual to submit a written

grievance and appeal his termination to the City Council, and the City Administrator

3 would then either review the Council’s recommendation and act accordingly, or

would carry out the binding decision of Council with submittal to the Mayor or City

Attorney within five working days of the decision or alleged incident. The City

maintains that McCorquodale did not submit a grievance to the Council, the acting

City Administrator, Human Resources, or the City Attorney within ninety days of

his termination, and therefore, he failed to comply with section 554.006 of the Act,

his claim is jurisdictionally barred, and his suit should be dismissed with prejudice

for want of subject-matter jurisdiction. The City contends that the fact that the City

Council terminated McCorquodale’s employment does not excuse his failure to

submit a grievance pertaining to his termination. In support of its Plea, the City

attached a Declaration of Ruby Beaven, the City Secretary. The following exhibits

are attached to her Declaration: McCorquodale’s acknowledgement that he received

and he had read the City’s Policies & Procedures Manual, the City of Montgomery

Policies & Procedures Manual, minutes from the November 18, 2024 City Council

Special Meeting when McCorquodale’s employment was terminated by vote of the

City Council, and an April 10, 2024 letter from McCorquodale to the City

Administrator regarding a different matter with an email acknowledging the receipt

of the letter.

McCorquodale filed his Response to Defendant’s Plea to the Jurisdiction,

arguing that the City’s grievance procedure states that it is a discretionary policy,

4 and he claims that when he attempted to file a grievance with the City, he was told

that the policy did not apply to actions taken by City Council and that he was not

required to follow the policy because he was no longer an employee. 1 According to

McCorquodale, he has established a prima facie case under the Texas Whistleblower

Act by showing that he reported a violation of law in good faith to an appropriate

legal authority, that he was in turn retaliated against and terminated, and the

retaliation would not have occurred but for his protected activity. McCorquodale

asserts that he took steps to initiate the grievance process, but his efforts were

intentionally frustrated by the City. He argues that because he has met his

jurisdictional requirements and satisfied his prima facie case, the City’s sovereign

immunity has been waived, and the trial court must deny the City’s Plea to the

Jurisdiction. In support of his Response, McCorquodale attached his affidavit, his

spouse’s affidavit, and a copy of section 6.16 of the City’s Policies & Procedures

Manual.

The trial court denied the City’s plea to the jurisdiction and this interlocutory

appeal followed. See Tex. Civ. Prac. & Rem. Code Ann. § 51.014(a)(8) (authorizing

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City of Montgomery v. David McCorquodale, Counsel Stack Legal Research, https://law.counselstack.com/opinion/city-of-montgomery-v-david-mccorquodale-texapp-2025.