Houston Community College v. the Hall Law Group, PLLC and Dolcefino Consulting and Scott Laha

CourtCourt of Appeals of Texas
DecidedJune 10, 2021
Docket01-20-00673-CV
StatusPublished

This text of Houston Community College v. the Hall Law Group, PLLC and Dolcefino Consulting and Scott Laha (Houston Community College v. the Hall Law Group, PLLC and Dolcefino Consulting and Scott Laha) 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
Houston Community College v. the Hall Law Group, PLLC and Dolcefino Consulting and Scott Laha, (Tex. Ct. App. 2021).

Opinion

Opinion issued June 10, 2021

In The

Court of Appeals For The

First District of Texas ———————————— NOS. 01-20-00673-CV 01-20-00689-CV 01-20-00690-CV 01-20-00691-CV 01-20-00692-CV 01-20-00693-CV 01-20-00694-CV 01-20-00695-CV ——————————— HOUSTON COMMUNITY COLLEGE, Appellant V. THE HALL LAW GROUP, PLLC, DOLCEFINO CONSULTING, AND SCOTT LAHA, Appellees

On Appeal from the 334th District Court Harris County, Texas Trial Court Case Nos. 2020-31380, 2020-31380A, 2020-31380B, 2020-31380C, 2020-31380D, 2020-31380E, 2020-31380F, 2020-31380G

MEMORANDUM OPINION Appellees, The Hall Law Group, PLLC (“Hall”), Dolcefino Consulting

(“Dolcefino”), and Scott Laha submitted various requests to appellant, Houston

Community College (“HCC”), for public information, pursuant to the Texas Public

Information Act (“TPIA”).1 Asserting that HCC refused to release the requested

information, appellees sought writs of mandamus to compel HCC to comply with

their requests.2 HCC filed a plea to the jurisdiction, arguing that the trial court lacked

subject matter jurisdiction over appellees’ claims because HCC is a governmental

body and that appellees failed to establish a waiver of governmental immunity under

the TPIA, i.e., that HCC had “refused” to act. The trial court found that HCC had

failed to comply with the TPIA, including provisions governing the suspension of

deadlines during an epidemic,3 and that such failure constituted a refusal to release

public information under the TPIA. The trial court denied HCC’s plea to the

jurisdiction and granted mandamus relief, ordering that HCC provide all public

1 See TEX. GOV’T CODE § 552.001–.376. 2 See id. § 552.321(a) (authorizing requestor to file suit for mandamus against governmental body that refuses to release public information). 3 See Act of May 17, 2019, 86th Leg., R.S., ch. 462, § 4, 2019 Tex. Gen. Laws 865, 866, amended by Act of May 11, 2021, 87th Leg., R.S., ch. 164, § 1 (S.B. 1225) (current version at TEX. GOV’T CODE § 552.233, “Temporary Suspension of Requirements for Governmental Body Impacted by Catastrophe”). Because the requests at issue were received, and this action was filed, prior to September 1, 2021, the effective date of the amendments, we apply the current version of the statute.

2 information responsive to appellees’ TPIA requests. The trial court granted

appellees’ motions to sever their requests into separate writs.4

In its sole issue in this interlocutory appeal,5 HCC contends that the trial court

erred in denying its plea to the jurisdiction.

We affirm.

Background

In its plea to the jurisdiction, HCC stated that, on December 11, 2019, Hall

served it with a request for public information under the TPIA, seeking seven

categories of documents pertaining to HCC’s Chief Human Resources Officer, Janet

May (“May”).6 On December 18, 2019, HCC acknowledged receipt of the request

and sought clarification. On January 2, 2020, Hall responded with another TPIA

4 Trial court case no. 2020-31380 is appellate cause no. 01-20-00673-CV. Trial court case no. 2020-31380A is appellate cause no. 01-20-00689-CV. Trial court case no. 2020-31380B is appellate cause no. 01-20-00690-CV. Trial court case no. 2020-31380C is appellate cause no. 01-20-00691-CV. Trial court case no. 2020-31380D is appellate cause no. 01-20-00692-CV. Trial court case no. 2020-31380E is appellate cause no. 01-20-00693-CV. Trial court case no. 2020-31380F is appellate cause no. 01-20-00694-CV. Trial court case no. 2020-31380G is appellate cause no. 01-20-00695-CV. 5 See TEX. CIV. PRAC. & REM. CODE § 51.014(a)(8). 6 The precise nature of the requests is not pertinent to this appeal. Generally, the requests sought documents regarding May’s job duties and work schedule; complaints filed against her or relating to her; documents authorizing her to perform services on behalf of The Harris Center for Mental Health and IDD (“The Harris Center”); and documents regarding the number of African Americans she had recommended or approved for termination.

3 request, seeking seven new categories of documents.7 HCC requested clarification

as to whether Hall’s response constituted a new or modified request. On January 7,

2020, Hall responded to both requests by consolidating them into one request

containing eleven items (“Request No. 1”). On January 17, 2020, HCC responded

to Hall, stating that, after a diligent search, it did not have records responsive to six

of the requested items and seeking clarification regarding the remaining five items.

On February 4, 2020, HCC sent a request to the Office of the Attorney General

(“OAG”), asking whether it was required to release information related to one of the

five remaining items. On February 10, 2020, HCC released records to Hall related

to two of the remaining items, and HCC notified Hall that it “did not have records

responsive to the last two of its requested items” and considered the request closed.

On March 4, 2020, Dolcefino submitted a TPIA request to HCC (“Request

No. 2”), seeking information concerning certain land sale contracts. Seven business

days later, however, HCC closed its offices for its scheduled Spring Break—March

16, 2020 through March 20, 2020. Thereafter, beginning on March 20, 2020 and

continuing thereafter, HCC “closed its offices indefinitely due to the COVID-19

pandemic.”

7 Generally, the requests involved documents relating to May’s work at The Harris Center and records showing any payments she had made or received for her work. 4 HCC asserted that, beginning in late March, “much of the country (indeed the

world) largely stopped functioning due to COVID-19.” And, “[a]mong the hundreds

of state and local pronouncements issued throughout Texas in response to the

pandemic, the [OAG] informed all governmental entities” that the computation of

“business days” under the TPIA was affected as follows:

If a governmental body has closed its physical offices for purposes of a public health or epidemic response or if a governmental body is unable to access its records on a calendar day, then such day is not a business day, even if staff continues to work remotely or staff is present but involved directly in the public health or epidemic response.

Accordingly, on April 3, 2020, HCC notified Dolcefino of HCC’s closure due

to the COVID-19 pandemic, stating that it would “process open records

requests . . . upon HCC’s return to normal operations/business days, in accordance

with the [TPIA] and the [OAG’s] guidelines,” as follows:

To protect the health and safety of our students, faculty, and staff with regard to COVID-19 (Coronavirus), [HCC] facilities are closed beginning March 20, 2020 until further notice. Due to the COVID-19 pandemic and the Texas Governor’s recent disaster declaration, HCC is following the Texas Attorney General’s guidelines regarding the [TPIA]. The Attorney General has clarified that if a governmental body has closed its physical offices for purposes of a public health or epidemic response or if a governmental body is unable to access its records on a calendar day, then such day is not a business day for purposes of the [TPIA], even if staff continues to work remotely or staff is present but involved directly in the public health or epidemic response. As such, HCC will process open records requests submitted during HCC’s closure/period of altered operations and will continue to process pending requests such as yours upon HCC’s return to normal operations/business days, in accordance with the [TPIA] and the Attorney General’s guidelines.

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Houston Community College v. the Hall Law Group, PLLC and Dolcefino Consulting and Scott Laha, Counsel Stack Legal Research, https://law.counselstack.com/opinion/houston-community-college-v-the-hall-law-group-pllc-and-dolcefino-texapp-2021.