Harris County, Texas v. Kenneth Bankhead

CourtCourt of Appeals of Texas
DecidedDecember 30, 2014
Docket01-13-01005-CV
StatusPublished

This text of Harris County, Texas v. Kenneth Bankhead (Harris County, Texas v. Kenneth Bankhead) 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
Harris County, Texas v. Kenneth Bankhead, (Tex. Ct. App. 2014).

Opinion

Opinion issued December 30, 2014

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-13-01005-CV ——————————— HARRIS COUNTY, TEXAS, Appellant V. KENNETH BANKHEAD, Appellee

On Appeal from the 80th District Court Harris County, Texas Trial Court Case No. 2012-69289

MEMORANDUM OPINION

Harris County brings this interlocutory appeal challenging the trial court’s

denial of its plea to the jurisdiction on the employment discrimination claim brought by Kenneth Bankhead under Chapter 21 of the Labor Code.1 The County

contends that the court lacked subject matter jurisdiction over Bankhead’s race

discrimination claim. In a cross-appeal, Bankhead argues that the portion of the

trial court’s order ruling that he is collaterally estopped from litigating at trial the

issue of whether he used excessive or unjustified force is in error. We reverse the

trial court’s order denying the County’s plea to the jurisdiction, render judgment

granting the plea to the jurisdiction, and dismiss the case for lack of subject matter

jurisdiction with prejudice.

Background

Bankhead was hired as a detention officer with the Harris County Sheriff’s

Office (HCSO) in 1991, became a deputy in 1994, and was later promoted to

sergeant in 2005. In December 2007, Bankhead was assigned to the County’s

Mental Health Unit and, in 2010, he was transferred to the unit’s housing floor.

The record reflects that Bankhead consistently received good performance

evaluations throughout his employment.

On January 26, 2011, Bankhead was instructed to check on inmate Vincent

Mastroianni after Mastroianni’s mother contacted the HCSO regarding her son’s

1 TEX. LAB. CODE ANN. § 21.051 (West 2006).

2 request for medical attention.2 When Bankhead arrived at Mastroianni’s cellblock,

a verbal altercation between the men ensued. Bankhead struck Mastroianni in the

face with his forearm resulting in a laceration above the inmate’s eye that required

fourteen sutures.3

In compliance with HCSO policy, Internal Affairs Division (IAD)

investigator Donald Althouse initiated an investigation of the incident 4 and

submitted his report to the Administrative Disciplinary Committee (ADC) for

review and recommendation.5 Citing “policy violations, unjustified use of force,”

the ADC recommended termination of Bankhead’s employment and the HCSO 2 Mastroianni’s mother called the sheriff’s office after her son asked to see a dentist due to mouth pain but received no response from jail personnel. 3 There is conflicting evidence as to whether the laceration was caused by Bankhead’s forearm or whether Matroianni lost his balance and, in doing so, struck his face against the wall. 4 HCSO policy requires that every incident involving use of force against an inmate in the jail be documented and reported to the division commander who determines whether to initiate an internal investigation. If an investigation is initiated, an IAD investigator conducts an investigation and presents his report to the Administrative Disciplinary Committee (ADC) for review and recommendation. If the ADC finds sustained misconduct and/or a violation of policy, it recommends appropriate disciplinary action against the employee. The employee may file a written notice of appeal to the Sheriff and, if the Sheriff or the Sheriff’s designee upholds the disciplinary action, the employee may then file a written notice of appeal with the Civil Service Commission. If the Commission upholds the disciplinary action against the employee, the employee may proceed with litigation. 5 The Committee at that time consisted of four members: Major Edwin Davis, then- Major Fred Brown (he subsequently became Chief Deputy), Captain Joe Hughes, and Major Ronnie Silvio (now retired). Davis and Brown are African-American and Hughes and Silvio are Caucasian.

3 sent a letter to Bankhead outlining the violations resulting in his termination on

July 29, 2011. Specifically, the HCSO found that Bankhead had violated Section

300, Policy #302 (“Professional Conduct Required”), II., subsection E.2; Policy

#303 (Conduct Prohibited”), I., subsections B, C.7 & 13 and D.14 & 17; Policy

#305 (“Performance of Duty”), I., subsections C & E; Policy #307 (“Supervisory

Responsibility”), I., subsection J; and Policy #501 (“Force, Arrest, and

Detention”), I., subsection A.11 of the HCSO’s policies and regulations. The letter

also stated that a review of Bankhead’s personnel history revealed that he was

involved “in an extraordinary amount of use of force incidents within the last three

(3) years.”6

The HCSO designee upheld the termination decision, and Bankhead

appealed his termination to the Civil Service Commission. Following a hearing on

March 22, 2012, the Commission upheld the HSCO’s decision based on the

specific policy violations enumerated in the termination letter.7

On November 21 2012, Bankhead filed suit against the County, alleging race

discrimination and retaliation under Chapter 21 of the Labor Code. See TEX. LAB.

6 The record reflects that Bankhead was involved in eight use-of-force incidents in his positon as sergeant, including the incident involving Mastroianni, between February 2008 and July 2011, when his employment was terminated. 7 We note that on Bankhead’s performance evaluation dated June 19, 2011—six months after the January 2011 incident and a little more than a month before the July 29, 2011 termination letter—he was evaluated as “above average” in nine of the fifteen categories and as “average” in the remaining six categories. 4 CODE ANN. § 21.051 (West 2006). The County moved for summary judgment and

the trial court granted the motion on Bankhead’s retaliation claim but denied it as

to his race discrimination claim. The County subsequently filed a plea to the

jurisdiction, Bankhead filed a response, and the County supplemented its plea. The

trial court’s denial of the plea to the jurisdiction precipitated the County perfecting

this interlocutory appeal.

Discussion

In its first and second issues, the County contends that the trial court erred in

denying its plea to the jurisdiction. Specifically, it argues that Bankhead failed to

present a prima facie case to support his race discrimination claim and, thus, the

trial court lacks subject matter jurisdiction over that claim.

A. Plea to the Jurisdiction

A plea to the jurisdiction is a dilatory plea that seeks dismissal of a case for

lack of subject matter jurisdiction. Harris Cnty. v. Sykes, 136 S.W.3d 635, 638

(Tex. 2004). The plaintiff has the burden to allege facts that affirmatively

demonstrate that the trial court has subject matter jurisdiction. Tex. Ass’n of Bus.

v. Tex. Air Control Bd., 852 S.W.2d 440, 446 (Tex. 1993). A plea to the

jurisdiction can be utilized to challenge whether the plaintiff has met his burden of

alleging jurisdictional facts, but it can also raise a challenge to the existence of

jurisdictional facts. See Tex. Dept. of Parks & Wildlife v. Miranda, 133 S.W.3d

5 217, 226–27 (Tex. 2004). Pleadings are construed liberally in favor of the pleader,

and all factual allegations are accepted as true. See id. at 226.

A trial court’s review of a plea to the jurisdiction challenging the existence

of jurisdictional facts mirrors that of a traditional motion for summary judgment.

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