Harris County v. A.D.

Texas Court of Appeals, 1st District (Houston)·Decided June 9, 2026·No. 01-24-01020-CV·Published

Opinion

Opinion issued June 9, 2026

In The

Court of Appeals

For The

First District of Texas

moved for a traditional and no-evidence summary judgment, arguing it retained governmental immunity from suit. The trial court denied the County’s plea and motions. We reverse.

Background

Before classes started on the morning of March 23, 2022, A.D. was struck by a car and injured while crossing the road near Dekaney High School. The car, driven by Elvis Hernandez, was traveling between thirty and forty miles per hour when it struck A.D. A member of the school staff who witnessed the accident reported that A.D. was walking with her head down, looking at what may have been a cell phone, and not keeping an eye on oncoming traffic as she crossed the road. 1 A.D. acknowledged that she saw Hernandez’s car approaching and believed she had enough time to cross the road. Hernandez was not cited.

The time of the accident is disputed. A.D. alleges that she was struck at 6:44 a.m., which is the time listed on the school district police department’s accident report. The County alleges the accident may have happened earlier, pointing to Hernandez’s deposition testimony that he struck A.D. at 6:20 a.m. and a different crash report listing the same “crash time.” What is undisputed, however, is that the accident occurred when it was dark, before the school-zone flashers were activated.

1 The same witness estimated Hernandez’s speed to be forty to fifty miles per hour.

When the school speed zone is not in effect, the speed limit is thirty-five miles per hour.

It is also undisputed that the County programmed the flashers to activate at 6:50 a.m. When activated, the flashers signal drivers to reduce their speed in the school zone.

A.D. and her guardian, Lisa Durant (whom we will refer to collectively as A.D.), asserted claims against the County under the Texas Tort Claims Act (TTCA).2 See TEX. CIV. PRAC. & REM. CODE §§ 101.001–.109. The petition alleges that the school-zone flashers are traffic-control devices which the County failed to properly maintain by programming them to start too late. In support, A.D. cites regulations for school speed zones in the Texas Administrative Code, which provide that the “[i]ntervals of operation” for signed zones “[g]enerally . . . should be in effect . . . from approximately 45 minutes before school opens until classes begin.” 43 TEX. ADMIN. CODE § 25.22(d)(3)(A)(i). Although Dekaney’s “school hours” were from 7:20 a.m. to 2:40 p.m., A.D. argues the County was legally required to activate the school-zone flashers “approximately 45 minutes” before student drop- off started at 6:50 a.m. And had the flashers been properly timed, Hernandez would have known to reduce his speed and likely could have avoided hitting A.D.

The County answered and filed a combined plea to the jurisdiction and traditional and no-evidence motion for summary judgment on governmental immunity. The County argued that it retained governmental immunity from suit

2 A.D. and Durant also sued Hernandez, who is still a party in the trial court but not on appeal, and three other governmental defendants, which she has nonsuited.

because the decision when to operate school zones is discretionary and the school-zone flashers were operating as intended and without any mechanical or other operational defect around the time of the accident.

An employee of the County’s engineering office testified by affidavit that the school-zone flashers are programmed and monitored through “the web-based Glance system,” which has been in place “for multiple years.” He explained:

The Glance system is used to program each school zone flasher to flash at a specified time based on the start and end times of the school’s calendar. Additionally, the Glance system remotely monitors the operational status of all components of each school zone flasher (e.g., beacon/lamp failure, voltage failure, accidental knocking down of the flasher by a motorist, and communications failure). The Glance system sends alerts to Harris County Engineering whenever there is a deficiency with any of the school zone flashers. Upon receipt of each alert, Harris County Engineering reviews the alert and if the flasher is absent, has a malfunction, or has some other condition needing repair, Harris County Engineering will dispatch a maintenance technician to the flasher to assess the issue and coordinate necessary repairs. Even if no issue is reported by the Glance system, Harris County inspects each school zone flasher at least once a year.

The school-zone flashers at issue were scheduled to operate on weekdays from 6:50 a.m. to 8:20 a.m., and according to the employee, “had no condition or malfunction negatively affecting their programmed operation.” The County also submitted maintenance and operational records for the flashers, along with guidance from the Texas Transportation Institute, prepared in cooperation with the Texas Department of Transportation and the Federal Highway Administration, recommending flashers

operate from approximately thirty minutes before until five minutes after classes begin.3 A.D. responded that although the County may have discretion in deciding whether to install the school-zone flashers in the first instance, the County’s discretion does not extend to the flashers’ timing. In A.D.’s view, once the County elected to install school-zone flashers near Dekaney High School, the County assumed a non-discretionary duty to operate the flashers with reasonable care, in accordance with regulations and known student arrival times.4 Further, she argues the County’s failure to activate the flashers before the student drop-off period began at 6:50 a.m.—despite a clear statutory directive and drop-off patterns—triggers the waiver of immunity in Sections 101.022(b) and 101.060(a)(2). See TEX. CIV. PRAC. & REM. CODE §§ 101.022(b) (regarding “the duty to warn of the absence, condition, or malfunction of traffic signs, signals, or warning devices as is required by Section

3 The recommendation is found in Appendix A to the document entitled “Guidelines for Traffic Control for School Areas,” which reflects that it was prepared in cooperation with the Texas Department of Transportation and the Federal Highway Administration and published in February 2009.

4 After the County filed its jurisdictional plea and summary-judgment motions, A.D.

filed a third amended petition asserting a negligent-implementation claim. She alleges that while courts have “held that the regulation of traffic is a governmental function that falls under the definition of a discretionary decision,” the County is subject to suit because “decisions incidental or related to the implementation of a discretionary or policy-formulated decision are not immune from liability.”

101.060”), .060(a)(2) (excluding claims arising from “the absence, condition, or malfunction of a traffic or road sign, signal, or warning device” from immunity waiver “unless the absence, condition, or malfunction is not corrected by the responsible governmental unit within a reasonable time after notice”).

The trial court denied the County’s jurisdictional plea and summary-judgment motions without explanation. The County appealed.

Governmental Immunity

The County argues that the trial court erred in denying its plea to the jurisdiction and motions for summary judgment because A.D.’s claims, based on the school-zone flashers being activated later than legally required, do not fall within the TTCA’s limited waiver of governmental immunity. A. Standard of review A plaintiff has the burden to show the trial court’s subject-matter jurisdiction.

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