Houston Forensic Science Center, Inc. v. Tammy Barette

Court of Appeals of Texas·Decided November 7, 2019·No. 01-19-00129-CV·Published

Opinion

Opinion issued November 7, 2019

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-19-00129-CV ——————————— HOUSTON FORENSIC SCIENCE CENTER, INC., Appellant V. TAMMY BARETTE, Appellee

On Appeal from the 234th District Court Harris County, Texas Trial Court Case No. 2018-81317

MEMORANDUM OPINION

Appellee Tammy Barette sued her former employer, appellant Houston

Forensic Science Center, Inc. (“HFSC”), for defamation relating to a press release

that accused her of misconduct as a crime scene investigator. In response to

HFSC’s motion to dismiss under the Texas Citizens Participation Act (“TCPA”), Barette nonsuited her claims against HFSC. See TEX. CIV. PRAC. & REM. CODE

§§ 27.001–.011. The trial court denied the TCPA motion to dismiss, and HFSC

filed this interlocutory appeal. See id. § 51.014(a)(12). On appeal, HFSC argues

that its TCPA motion survived Barette’s nonsuit because it requested attorney’s

fees, costs, expenses, and sanctions. HFSC also argues that the trial court erred by

denying its motion to dismiss on the merits.

Because we conclude that the trial court’s order denying the motion to

dismiss is void, we vacate the order and dismiss this appeal.

Background

HFSC is a local government corporation that was created by the City of

Houston to operate an independent center for analysis of forensic evidence.

Barette, who has a Ph.D. in Biological Anthropology, worked for HFSC as a crime

scene investigator. HFSC asserts that it terminated her employment because she

failed to follow policies regarding the equipment used to test evidence.

After HFSC terminated Barette’s employment, it issued a press release

stating that a crime scene investigator had been terminated due to the use of testing

equipment that led to false negative results. Later, employees of HFSC identified

Barette to news organizations, which identified her by name in their reporting.

Barette sued HFSC for defamation per se based on the press release. She

denied the allegations in the press release and later news stories, asserting that they

2 included multiple false statements. HFSC filed a combined plea to the jurisdiction

and motion to dismiss Barette’s claim for defamation per se under the TCPA.

HFSC argued that Barette could not prove a prima facie case of defamation per se

with clear and specific evidence. HFSC specifically challenged Barette’s ability to

show falsity, fault, and damages. HFSC also argued that it was entitled to dismissal

under the TCPA because it was immune from intentional torts under the Texas

Tort Claims Act (“TTCA”). HFSC requested “affirmative relief” of “court costs,

reasonable attorney’s fees, other expenses incurred in defending the claim as

justice and equity may require,” and sanctions.

Three days after HFSC filed its combined motion, Barette amended her

petition, dropping claims of defamation per se against HFSC and adding claims of

defamation per se against four employees of HFSC. HFSC filed a supplemental

brief on its pending TCPA motion to dismiss, arguing that its request for attorney’s

fees, costs, and expenses under the TCPA survived Barette’s nonsuit.

The trial court denied both the plea to the jurisdiction and the TCPA motion

to dismiss, and HFSC appealed.

Analysis

On appeal, HFSC raises two issues, challenging only the trial court’s ruling

on the TCPA dismissal motion.

3 The procedural posture of this case is unusual. In the trial court, HFSC

challenged the same claim—defamation per se—by asserting both that the court

lacked subject-matter jurisdiction due to governmental immunity and by asking the

court to dismiss the claim and award attorney’s fees, costs, expenses, and

sanctions. When a court lacks subject matter jurisdiction because a party is

“immune from a pending claim, any court decision regarding that claim is advisory

to the extent it addresses issues other than immunity, and the Texas Constitution

does not afford courts jurisdiction to make advisory decisions or issue advisory

opinions.” Rusk State Hosp. v. Black, 392 S.W.3d 88, 95 (Tex. 2012).

Sovereign immunity is a common-law doctrine that protects the state from

suit or liability unless there exists an express constitutional or statutory waiver of

immunity. See City of Houston v. Williams, 353 S.W.3d 128, 134 (Tex. 2011);

Tooke v. City of Mexia, 197 S.W.3d 325, 331 (Tex. 2006). “Governmental

immunity operates like sovereign immunity to afford similar protection to

subdivisions of the State, including counties, cities, and school districts.” Harris

Cty. v. Sykes, 136 S.W.3d 635, 638 (Tex. 2004). Ordinarily, an entity claiming

governmental immunity is a political subdivision. Rosenberg Dev. Corp. v.

Imperial Performing Arts, Inc., 571 S.W.3d 738, 748 (Tex. 2018). However, when

“the governing statutory authority demonstrates legislative intent to grant an entity

the ‘nature, purposes, and powers’ of an ‘arm of the State government,’ that entity

4 is a government unit unto itself.” Ben Bolt-Palito Blanco Consol. Indep. Sch. Dist.

v. Tex. Political Subdivisions Prop./Cas. Joint Self-Ins. Fund, 212 S.W.3d 320, 325

(Tex. 2006) (citing Harris Cty. Flood Control Dist. v. Mann, 140 S.W.2d 1098,

1101 (Tex. 1940)).

A local government corporation may be created under the authority of the

Transportation Code “to aid and act on behalf of one or more local governments to

accomplish any governmental purpose of those local governments.” TEX. TRANSP.

CODE § 431.101(a). A local government corporation is defined as “a governmental

unit as that term is used” in the TTCA, and its operations are expressly defined as

“governmental, not proprietary, functions.” Id. § 431.108. Thus, the Transportation

Code demonstrates the legislative intent for local government corporations to be

governmental units protected by governmental immunity. See Rosenberg Dev.

Corp., 571 S.W.3d at 748; Ben Bolt-Palito, 212 S.W.3d at 325; Ray Ferguson

Interests, Inc. v. Harris Cty. Sports & Convention Corp., 169 S.W.3d 18, 22 (Tex.

App.—Houston [1st Dist.] 2004, no pet.) (concluding that a local governmental

corporation was protected by governmental immunity).

The TTCA provides a limited waiver of sovereign or governmental

immunity for certain negligent acts by governmental employees. TEX. CIV. PRAC.

& REM. CODE § 101.021; see Mission Consol. Indep. Sch. Dist. v. Garcia, 253

S.W.3d 653, 655 (Tex. 2008) (TTCA is limited waiver of both sovereign and

5 governmental immunity); Rogge v.

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