El Paso County Juvenile Board v. Dolores Aguilar

Procedural entryThis page is a short order in El Paso County Juvenile Board v. Dolores Aguilar. Read the opinion of the Court — 2012 Tex. App. LEXIS 3672
Court of Appeals of Texas·Decided May 9, 2012·No. 08-11-00206-CV·Published

Opinion

                                                           COURT OF APPEALS

                                                   EIGHTH DISTRICT OF TEXAS

                                                              EL PASO, TEXAS

EL PASO COUNTY JUVENILE

BOARD,

                                    Appellant,

v.

DOLORES AGUILAR,

                                    Appellee.

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                  No. 08-11-00206-CV

                         Appeal from

34th District Court

of El Paso County, Texas

(TC # 2009-667)

                                                                  O P I N I O N

The El Paso County Juvenile Board appeals from an interlocutory order denying its plea to the jurisdiction.  For the reasons that follow, we reverse.

FACTUAL SUMMARY

            Dolores Aguilar filed suit alleging that the Juvenile Board terminated her employment in violation of Chapter 451 of the Texas Labor Code because she filed a claim for worker’s compensation.  A few days after the Supreme Court issued Travis Central Appraisal District v. Norman, 342 S.W.3d 54 (Tex. 2011), the Juvenile Board filed a plea to the jurisdiction asserting that it is immune from suit because it is a political subdivision and its immunity has not been waived.  Aguilar responded that Norman did not control because the Juvenile Board is not a political subdivision.  The trial court denied the plea to the jurisdiction.  The Juvenile Board timely filed its notice of accelerated appeal.  See Tex.Civ.Prac.&Rem.Code Ann. § 51.014 (a)(8)(West Supp. 2011).

NO WAIVER OF IMMUNITY

            In its sole issue, the Juvenile Board argues that the trial court lacks subject matter jurisdiction because it is a political subdivision under Section 504.001 of the Texas Labor Code and its governmental immunity from suit has not been waived.  Aguilar concedes in her brief that the Juvenile Board is a political subdivision as defined in Section 504.001(3) of the Labor Code and that Norman controls this appeal.  Despite Aguilar’s concession, we will address the issue as subject matter jurisdiction cannot be conferred by consent, waiver, or estoppel.  See Van Independent School District v. McCarty, 165 S.W.3d 351, 354 (Tex. 2005); Dubai Petroleum Co. v. Kazi, 12 S.W.3d 71, 76 (Tex. 2000).

            Sovereign immunity protects the State, its agencies, and its officials from lawsuits for damages.  Ben Bolt-Palito Blanco Consolidated Independent School District v. Texas Political Subdivisions Property/Casualty Joint Self-Insurance Fund, 212 S.W.3d 320, 323-24 (Tex. 2006).  The common-law doctrine of governmental immunity likewise protects political subdivisions of the state.  Id., 212 S.W.3d at 324.  A political subdivision enjoys governmental immunity from suit to the extent that it has not been abrogated by the Legislature.  Id.

            We review a trial court’s ruling on a plea to the jurisdiction de novo.  Texas Department of Parks and Wildlife v. Miranda, 133 S.W.3d 217, 228 (Tex. 2004).  Where, as here, the jurisdictional question is limited to the sufficiency of the plaintiff’s pleadings, we will accept as true all factual allegations in the petition to determine if the plaintiff has met her burden to allege facts which affirmatively demonstrate a waiver.  Miranda, 133 S.W.3d at 224.  

Aguilar filed suit alleging that the Juvenile Board retaliated by discharging her because she filed a worker’s compensation claim.  Section 451.001 specifically prohibits an employer from retaliating against an employee because the employee files a good faith claim for worker’s compensation.  See Tex.Labor Code Ann. § 451.001(1)(West 2006).  An employee who is terminated or discriminated against in violation of Section 451.001 has a cause of action against the employer for damages incurred as a result of the violation.  See Tex.Lab.Code Ann. § 451.002.  A cause of action based on Chapter 451 cannot proceed against a governmental entity absent Legislative consent to the suit.  Texas Workforce Commission v. Olivas, 349 S.W.3d 174, 176 (Tex.App.--El Paso 2011, pet. filed).  To the extent immunity may be waived, that waiver is provided by the State Applications Act (SAA) found in Chapter 501 of the Labor Code or by the Political Subdivisions Law (PSL) found in chapter 504 of the Labor Code.  See Tex.Lab.Code Ann. §§ 501.001-501.051 (West 2006 & West Supp. 2011)(the SAA); Tex.Lab.Code Ann. §§ 504.001-504.073 (The PSL).  The SAA and the PSL make many of the provisions of the worker’s compensation system applicable to the state (the SAA) and political subdivisions of the state (the PSL).  See Tex.Lab.Code Ann. § 501.001(6)(SAA); Tex.Lab.Code Ann. § 504.001(3)(PSL). 

Both the SAA and the PSL provide that Chapter 451, the Anti-Retaliation Law, is included within the SAA and PSL except to the extent it is inconsistent with the provisions of these chapters. 

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El Paso County Juvenile Board v. Dolores Aguilar, (Tex. Ct. App. 2012).

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Related

Texas Department of Parks & Wildlife v. Miranda
133 S.W.3d 217 (Texas Supreme Court, 2004)
Van Independent School District v. McCarty
165 S.W.3d 351 (Texas Supreme Court, 2005)
Travis Central Appraisal District v. Norman
342 S.W.3d 54 (Texas Supreme Court, 2011)
Dubai Petroleum Co. v. Kazi
12 S.W.3d 71 (Texas Supreme Court, 2000)
Guaranty Petroleum Corp. v. Armstrong
609 S.W.2d 529 (Texas Supreme Court, 1980)
El Paso County v. Solorzano
351 S.W.3d 577 (Court of Appeals of Texas, 2011)
Texas Workforce Commission v. Olivas
349 S.W.3d 174 (Court of Appeals of Texas, 2011)