Donna Cotton v. Montgomery County Civil Service Commission and Montgomery County, Texas

Texas Court of Appeals, 9th District (Beaumont)·Decided March 26, 2026·No. 09-24-00083-CV·Published

Opinion

In The

Court of Appeals

Ninth District of Texas at Beaumont

NO. 09-24-00083-CV

DONNA COTTON, Appellant

V.

MONTGOMERY COUNTY CIVIL SERVICE COMMISSION AND MONTGOMERY COUNTY, TEXAS, Appellees

On Appeal from the 457th District Court Montgomery County, Texas

Trial Cause No. 23-02-02104-CV

MEMORANDUM OPINION

Donna Cotton (“Cotton”), a Montgomery County Sheriff’s Office dispatcher supervisor, appealed her demotion and two-day suspension to the Montgomery County Civil Service Commission (the “Commission”), and once the Commission upheld same, she appealed to a Montgomery County District Court pursuant to section 158.012 of the Texas Local Government Code. See Tex. Loc. Gov’t Code

Ann. § 158.012. Cotton now challenges Summary Judgment Orders in favor of Montgomery County, Texas (the “County”). She argues that it was error to grant the County’s No-Evidence and Traditional Motions for Summary Judgment because evidence was submitted outside the confines of the grievance hearing to the Commissioners and because the Commissioners refused Cotton’s appeal of the two- day suspension. We hold that the District Court did not err in granting the County’s No-Evidence Motion for Summary Judgment and that the Montgomery County Civil Service Regulations (the “Regulations”) permitting appeal of suspensions of more than three days is not contrary to law. For the reasons discussed below, we affirm the District Court’s Order granting summary judgment.

Background

In February 2023, Cotton filed Plaintiff’s Original Petition against the County and the Commission. In the Petition, Cotton appealed the Commission’s decision made on January 30, 2023, pursuant to section 158.012 of the Texas Local Government Code. See id. § 158.012(a) (authorizing an appeal of a final decision by the commission by a county employee by filing a petition in district court within 30 days of the decision). Cotton petitioned for reversal of the decision pursuant to section 158.0121. See id. § 158.0121 (requiring the district court to review the commission’s decision under the substantial evidence rule). Cotton requested that

she be permitted to present additional evidence about procedural irregularities at the grievance hearing. Cotton requested that the Commission’s decision be set aside and that the District Court reverse the Commission’s decision, order back pay and benefits, purge her personnel file of documents and materials related to the disciplinary action subject of this appeal, and all court costs and attorney’s fees.

On April 12, 2023, the County and the Commission filed Defendants’ Answer and Special Exception and generally denied all Cotton’s allegations and pleaded the affirmative defense of governmental immunity. Defendants’ Answer included a special exception to Cotton’s Petition because it failed to give sufficient notice of the “procedural irregularities” at the grievance hearing.

On May 23, 2023, Cotton filed Plaintiff’s First Amended Original Petition and alleged that she was disciplined by the Montgomery County Sheriff’s Office with a demotion and two-day unpaid suspension. Cotton stated that she appealed the discipline, and a hearing was held on January 30, 2023. According to Cotton, the demotion was upheld but she was not permitted to appeal the two-day suspension per the Commission, based on the local rule on suspensions of three days or less. Cotton pointed out that she later learned that before the hearing, the Commission received evidence from the County and that this submission of evidence outside the

hearing deprived her of a fair hearing and due process. Cotton requested relief identical to the relief requested in Plaintiff’s Original Petition.

On January 12, 2024, the Commission filed Montgomery County Civil Service Commission’s Plea to the Jurisdiction. In the Plea, the Commission argued that it is not a separate legal entity and lacks the legal capacity to be sued. The Commission argued that alternatively, governmental immunity bars Cotton’s action and deprives the Court of subject-matter jurisdiction against it.

That same day, the County and the Commission filed Defendants’ No-

Evidence Motion for Summary Judgment and separately, Defendants’ Motion for Summary Judgment. Both summary judgments were subject to the Plea to the Jurisdiction filed on behalf of the Commission. In the No-Evidence Motion for Summary Judgment, the County and the Commission argued that Cotton presented no evidence that she was deprived of a fair hearing or due process, that the Commission’s decision was not supported by substantial evidence, or that the Commission could be sued. The County and the Commission argued that before the hearing, Cotton had notice of all exhibits that would be offered and that Cotton presented no evidence that: she was denied a fair hearing or due process; she was not allowed to present evidence at the hearing; she was not allowed to review and challenge all evidence provided to the Commission before the hearing’s conclusion;

she was not allowed to cross-examine witnesses; or she was not allowed to rebut, object to, or cross-examine witnesses and evidence.

In Defendants’ Motion for Summary Judgment, the County asserted that in September 2022, Cotton, a dispatcher supervisor with the Montgomery County Sheriff’s Office (“MCSO”), received official written notice that she was the subject of an investigation for violating the policies of MCSO between April and September 2022. Cotton was accused of “engaging in behavior, in her position as a supervisor, that had the effect of demeaning, humiliating, and intimidating subordinates in her command.” At the time of Cotton’s alleged misbehavior, Cotton had been disciplined and was on probation for similar behavior. As a result of the investigation, Cotton was found to have violated four policies that included: (1) engaging in any behavior meant to or which has the effect of intimidating or humiliating another individual including bullying, gossiping, harassment, and verbal abuse; (2) acting, on or off duty, in a manner that discredits the MCSO; (3) violating the MCSO policy that requires all employees to conduct themselves in a manner which does not bring about a question of integrity and exhibits the highest degree of professionalism; and (4) violating the rules and regulations of the Civil Service Commission, Commissioners Court, or the hiring authority. Cotton was suspended

for two days, demoted to dispatcher, and her probationary period was extended an additional six months.

In November 2022, the County Sheriff upheld the finding and disciplinary actions, and Cotton then completed the Employee Grievance Form appealing the demotions and suspension to the Commission. On December 22, 2022, the Commission responded to Cotton’s grievance and indicated that a suspension of two days could not be grieved, but that the demotion could, and therefore, only the demotion should be presented. On January 30, 2023, the Commission heard testimony from seven witnesses and admitted thirty-nine exhibits submitted by the County. The Commission did not exclude or limit any witnesses, testimony, exhibits or evidence submitted by Cotton. The Commission ultimately affirmed Cotton’s demotion and removed the six-month probationary period from her record.

The Summary Judgment Motion detailed the testimony of the seven current and former MCSO employees, including Cotton, that testified at the hearing about Cotton’s behavior and the investigation of the allegations against Cotton. The Motion stated that the thirty-nine exhibits admitted included statements from other employees, details of the investigation, performance reports, progress reports, and copies of the policies Cotton violated.

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Donna Cotton v. Montgomery County Civil Service Commission and Montgomery County, Texas, (Tex. Ct. App. 2026).

Donna Cotton v. Montgomery County Civil Service Commission and Montgomery County, Texas (Donna Cotton v. Montgomery County Civil Service Commission and Montgomery County, Texas) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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