Columbus Independent School District v. Five Oaks Achievement Center

CourtCourt of Appeals of Texas
DecidedApril 21, 2005
Docket14-04-00129-CV
StatusPublished

This text of Columbus Independent School District v. Five Oaks Achievement Center (Columbus Independent School District v. Five Oaks Achievement Center) 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
Columbus Independent School District v. Five Oaks Achievement Center, (Tex. Ct. App. 2005).

Opinion

Affirmed and Opinion filed April 21, 2005

Affirmed and Opinion filed April 21, 2005.

In The

Fourteenth Court of Appeals

_______________

NO. 14-04-00129-CV

COLUMBUS INDEPENDENT SCHOOL DISTRICT, Appellant

V.

FIVE OAKS ACHIEVEMENT CENTER, Appellee

____________________________________________________________________

On Appeal from the County Court at Law

Austin County, Texas

Trial Court Cause No. 03CV3724

____________________________________________________________________

O P I N I O N


In this accelerated interlocutory appeal,[1] Columbus Independent School District (ACISD@) appeals the denial of its plea to the jurisdiction on the grounds that: (1) Texas Education Code section 11.151 does not provide a waiver of its immunity from suit; (2) a school district cannot waive such immunity by conduct; and (3) Five Oaks Achievement Center (AFive Oaks@) did not adequately exhaust its administrative remedies before filing suit. We affirm.

Background

Five Oaks sued CISD to collect payments allegedly due on a contract to provide special education services.  CISD filed a plea to the jurisdiction, claiming immunity from suit and failure to exhaust administrative remedies, which the trial court denied.

Immunity from Suit

Governmental immunity provides immunity from suit to subdivisions of a state, including school districts.  Harris County v. Sykes, 136 S.W.3d 635, 638 (Tex. 2004).  When a governmental unit contracts with a private party, it thereby waives immunity from liability, but not immunity from suit.  Catalina Dev., Inc. v. County of El Paso, 121 S.W.3d 704, 705 (Tex. 2003).  As applicable to this case,[2] immunity from suit can be waived only by a constitutional provision or legislative enactment that is expressed in clear and unambiguous language.  Wichita Falls Hosp. v. Taylor, 106 S.W.3d 692, 695B96 (Tex. 2003).  A party suing a governmental entity must establish the State=s waiver of immunity from suit.  Tex. Dep=t of Transp. v. Jones, 8 S.W.3d 636, 638 (Tex. 1999).  A trial court=s ruling on a plea to the jurisdiction based on immunity from suit is reviewed de novo.  Tex. Natural Res. Conservation Comm=n v. IT-Davy, 74 S.W.3d 849, 855 (Tex.  2002).

The statute upon which Five Oaks relies to provide a waiver of CISD=s immunity from suit is section 11.151 of the Texas Education Code (“section 11.151”):

The trustees of an independent school district constitute a body corporate and in the name of the district may acquire and hold real and personal property, sue and be sued, and receive bequests and donations or other moneys or funds coming legally into their hands.


Tex. Educ. Code Ann. ' 11.151 (Vernon Supp. 2004-05) (emphasis added).  In Missouri Pacific, the Texas Supreme Court (the ACourt@) held that a statute similarly authorizing navigation districts to Asue and be sued@ was a Ageneral consent for [the] District to be sued in the courts of Texas in the same manner as other defendants@ and that the District was therefore a Apolitical subdivision that is always subject to suit by virtue of a general statute  . . . .@  Mo. Pac. R.R. Co. v. Brownsville Navigation Dist., 453 S.W.2d 812, 813B14 (Tex. 1970).  Based on this conclusion, the Court reversed the decisions of the lower courts that had granted the district=s plea to the jurisdiction based on immunity from suit.  Id. at 814.


Thereafter, the Legislature added section 311.034 to the Government Code, providing, AIn order to preserve the legislature=s interest in managing state fiscal matters through the appropriations process, a statute shall not be construed as a waiver of sovereign immunity unless the waiver is effected by clear and unambiguous language.@  Tex. Gov=t Code Ann. ' 311.034 (Vernon Supp. 2004). 

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Related

Harris County v. Sykes
136 S.W.3d 635 (Texas Supreme Court, 2004)
Texas Natural Resource Conservation Commission v. IT-Davy
74 S.W.3d 849 (Texas Supreme Court, 2002)
Catalina Development, Inc. v. County of El Paso
121 S.W.3d 704 (Texas Supreme Court, 2003)
Wichita Falls State Hospital v. Taylor
106 S.W.3d 692 (Texas Supreme Court, 2003)
Texas Department of Transportation v. Jones
8 S.W.3d 636 (Texas Supreme Court, 1999)
Travis County v. Pelzel & Associates, Inc.
77 S.W.3d 246 (Texas Supreme Court, 2002)
In Re Entergy Corp.
142 S.W.3d 316 (Texas Supreme Court, 2004)
Duhart v. State
610 S.W.2d 740 (Texas Supreme Court, 1980)
Missouri Pacific Railroad v. Brownsville Navigation District
453 S.W.2d 812 (Texas Supreme Court, 1970)
Texas Prison Board v. Cabeen
159 S.W.2d 523 (Court of Appeals of Texas, 1942)
Warren v. Sanger Independent School Dist.
288 S.W. 159 (Texas Commission of Appeals, 1926)

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Bluebook (online)
Columbus Independent School District v. Five Oaks Achievement Center, Counsel Stack Legal Research, https://law.counselstack.com/opinion/columbus-independent-school-district-v-five-oaks-a-texapp-2005.