In Re Agua Special Utility District v. the State of Texas

CourtCourt of Appeals of Texas
DecidedJuly 17, 2025
Docket13-25-00041-CV
StatusPublished

This text of In Re Agua Special Utility District v. the State of Texas (In Re Agua Special Utility District v. the State of Texas) 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.

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In Re Agua Special Utility District v. the State of Texas, (Tex. Ct. App. 2025).

Opinion

NUMBER 13-25-00041-CV

COURT OF APPEALS

THIRTEENTH DISTRICT OF TEXAS

CORPUS CHRISTI – EDINBURG

IN RE AGUA SPECIAL UTILITY DISTRICT

ON PETITION FOR WRIT OF MANDAMUS

MEMORANDUM OPINION

Before Chief Justice Tijerina and Justices West and Fonseca Memorandum Opinion by Justice West 1

By petition for writ of mandamus, Agua Special Utility District (Agua) contends that

the trial court 2 abused its discretion by: (1) ordering it to engage in discovery on the merits

before ruling on its plea to the jurisdiction; and (2) ordering the production of irrelevant

project files and financial records. We conditionally grant the petition for writ of mandamus

1 See TEX. R. APP. P. 52.8(d) (“When denying relief, the court may hand down an opinion but is not

required to do so. When granting relief, the court must hand down an opinion as in any other case.”); id. R. 47.4 (distinguishing opinions and memorandum opinions). 2 This original proceeding arises from trial court cause number C-3353-20-I in the 398th District

Court of Hidalgo County, Texas, and the respondent is the Honorable Keno Vasquez. See id. R. 52.2. in part and deny it in part.

I. BACKGROUND

Agua contracted with real party in interest O.G. Construction Company, L.L.C.

(OG) and other entities for the construction and installation of the Palmview Wastewater

Collection System in Hidalgo County, Texas. The Palmview Wastewater Collection

System consisted of a five-phase project to replace septic systems with a regional sewer

system. In this regard, OG entered into a contract with Agua whereby OG would install

gravity sewer lines on Phase I—Group A&G of the five-phase project. However, the

parties’ relationship deteriorated, and Agua ultimately terminated OG’s contract.

OG subsequently intervened in a pending lawsuit filed against Agua by S&B

Infrastructure, Ltd., Agua’s engineer on the project. OG asserted that Agua breached its

contract, violated the Texas Prompt Payment Act and the Texas Trust Fund Act, and

committed ultra vires actions. OG sought recovery in quantum meruit, damages, and

injunctive and declaratory relief. OG contended in relevant part that the project was

underfunded and Agua reallocated project funds that were intended to be used for

contract payments in Phase I rather than pay OG as required under the contract. Agua

thereafter filed a counterclaim against OG for breach of contract, alleging that its work on

the project was deficient and that OG abandoned the contract.

On August 2, 2024, more than two years after OG intervened in the lawsuit, Agua

filed a combined “Plea to the Jurisdiction and Traditional and No Evidence Motion for

Partial Summary Judgment” pertaining to OG’s claims against it. Agua alleged that it was

immune from suit pursuant to § 271.153 of the Texas Local Government Code and it

2 sought “a dismissal or take-nothing judgment as to O.G.’s affirmative claims because

each claim fails as a matter of law because of sovereign immunity, common law

construction law doctrines, or express contractual terms.” See TEX. LOC. GOV’T CODE ANN.

§§ 271.151–.160 (governing the adjudication of claims arising under written contracts with

local governmental entities).

The trial court originally set Agua’s combined plea for hearing on September 17,

2024. However, on September 3, 2024, OG filed a motion to continue the hearing to

secure additional time for discovery. Over Agua’s objections, the trial court deferred

hearing on Agua’s combined plea to allow discovery. Thereafter, OG filed a motion to

compel discovery and Agua filed responsive pleadings thereto. The trial court issued an

order granting OG’s motion to compel; however, the parties disagreed regarding the

interpretation of that order. On October 24, 2024, the trial court signed an amended order

granting OG’s motion to compel and signed a second amended order granting OG’s

motion to compel on January 7, 2025.

This original proceeding ensued. Agua filed this petition for writ of mandamus and

an opposed amended emergency motion seeking to stay all discovery in the trial court.

We granted Agua’s opposed amended emergency motion to stay, and we ordered all

discovery to be stayed. See TEX. R. APP. P. 52.10. We requested and received a response

to the petition for writ of mandamus from OG and a reply thereto from Agua.

II. STANDARD OF REVIEW

Mandamus is an extraordinary and discretionary remedy. See In re Allstate Indem.

Co., 622 S.W.3d 870, 883 (Tex. 2021) (orig. proceeding); In re Garza, 544 S.W.3d 836,

3 840 (Tex. 2018) (orig. proceeding) (per curiam); In re Prudential Ins. Co. of Am., 148

S.W.3d 124, 138 (Tex. 2004) (orig. proceeding). The relator must show that (1) the trial

court abused its discretion, and (2) the relator lacks an adequate remedy on appeal. In re

USAA Gen. Indem. Co., 624 S.W.3d 782, 787 (Tex. 2021) (orig. proceeding); In re

Prudential Ins. Co. of Am., 148 S.W.3d at 135–36; Walker v. Packer, 827 S.W.2d 833,

839–40 (Tex. 1992) (orig. proceeding).

III. MERITS DISCOVERY

In its first issue, Agua asserts that the trial court abused its discretion by ordering

discovery on the merits of OG’s lawsuit before ruling on Agua’s plea to the jurisdiction. In

contrast, OG contends that Agua’s jurisdictional “arguments are intertwined to a

significant degree with the facts on the merits,” and thus, the trial court did not abuse its

discretion in proceeding with discovery.

Generally, a ruling on jurisdiction should be made “as soon as practicable.” Tex.

Dep’t of Parks & Wildlife v. Miranda, 133 S.W.3d 217, 227 (Tex. 2004). It is a “fundamental

precept that a court must not proceed on the merits of a case until legitimate challenges

to its jurisdiction have been decided.” Id. at 228; see W. Travis Cnty. Pub. Util. Agency v.

CCNG Dev. Co., 514 S.W.3d 770, 776 (Tex. App.—Austin 2017, no pet.); see also In re

City of Edinburg, No. 13-23-00131-CV, 2023 WL 3185808, at *4 (Tex. App.—Corpus

Christi–Edinburg May 1, 2023, orig. proceeding) (mem. op.). That said, the trial court

“should hear evidence as necessary to determine the [jurisdictional] issue before

proceeding with the case.” Bland Indep. Sch. Dist. v. Blue, 34 S.W.3d 547, 554 (Tex.

2000). “Whether a determination of subject-matter jurisdiction can be made in a

4 preliminary hearing or should await a fuller development of the merits of the case must

be left largely to the trial court’s sound exercise of discretion.” Id.; see County of El Paso

v. Aguilar, 600 S.W.3d 62, 81 (Tex. App.—El Paso 2020, no pet.).

“Consistent with these tenets, several Texas courts of appeals have concluded that

a trial court abuses its discretion when it delays ruling on a jurisdictional plea for the

purpose of allowing discovery unnecessary to the jurisdictional challenge.” In re Bexar

Medina Atascosa Cntys. Water Control & Improvement Dist. No. One, No. 04-24-00538-

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Related

Texas Department of Parks & Wildlife v. Miranda
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In Re Exmark Manufacturing Co.
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