Jill Morphis, Shila Borchert, Tommy Hunter, Jennie Flaa, and Mike Picha v. Justin Walton and Mariah Walton, A/N/F P.W.

Texas Court of Appeals, 2nd District (Fort Worth)·Decided July 9, 2026·No. 02-25-00691-CV·Published

Opinion

In the

Court of Appeals

Second Appellate District of Texas at Fort Worth

No. 02-25-00691-CV

JILL MORPHIS, SHILA BORCHERT, TOMMY HUNTER, JENNIE FLAA, AND MIKE PICHA, Appellants

V.

JUSTIN WALTON AND MARIAH WALTON, A/N/F P.W., Appellees

On Appeal from the 467th District Court Denton County, Texas

Trial Court No. 25-11727-467

Before Sudderth, C.J.; Kerr and Womack, JJ.

Memorandum Opinion by Justice Womack

MEMORANDUM OPINION

I. INTRODUCTION

Sanger Independent School District employees Jill Morphis, Shila Borchert, Tommy Hunter, Jennie Flaa, and Mike Picha (the ISD Employees) appeal from a trial court order denying their plea to the jurisdiction in a suit filed by Justin and Mariah Walton, the parents of a Sanger ISD student who allegedly had been subjected repeatedly to verbal threats by another Sanger ISD student who attended the same school and rode the same bus. In three issues, the ISD Employees contend that the trial court erred by denying their plea to the jurisdiction because (1) the Waltons failed to exhaust their administrative remedies before filing suit, (2) the ISD Employees’ immunity from suit for the Waltons’ ultra vires claim has not been waived, and (3) the trial court’s order requiring the ISD Employees to complete a threat assessment is not relief envisioned by the Uniform Declaratory Judgments Act (UDJA). We reverse the trial court’s order and dismiss the Waltons’ suit for want of jurisdiction.

II. BACKGROUND

The Waltons sued the ISD Employees in November 2025, claiming that the ISD Employees had failed to comply with ministerial duties imposed by Section 37.115 of the Texas Education Code and the Sanger ISD Board Policy Manual “after being informed of ‘harmful, threatening or violent behavior’”1 toward

1 For readability, the record quotations in this memorandum opinion omit formatting in the original, such as boldface type and underlining.

their daughter (Paula)2 “including verbal threats, such as threats to kill [her]; threats of the use of a weapon, such as statements about knowing where guns are; [and] harmful statements, such as telling a[] student to kill” herself. They alleged that another elementary-school student (David) had been threatening to harm their daughter for at least two years and that the ISD Employees had been aware of the threats since they had begun but had failed to take sufficient steps to secure Paula’s safety as required by law and Sanger ISD policy.

The Waltons sought a temporary restraining order and temporary injunction seeking (1) to have David temporarily removed from the elementary-school campus, (2) to not allow David on any Sanger ISD buses, and (3) to prohibit David from attending any of the elementary school’s events or school-sponsored events. The Waltons also sought a declaration that the ISD Employees had failed to carry out their ministerial duties according to Texas Education Code Section 37.115 and the Sanger ISD Board Policy Manual. Further, the Waltons sought attorney’s fees.

The ISD Employees filed a plea to the jurisdiction alleging (1) that the Waltons had failed to exhaust their administrative remedies by failing to first seek relief from the Texas Commissioner of Education, (2) that each of the ISD Employees is entitled to governmental immunity from the Waltons’ claims as pleaded,3 and (3) that the

In this memorandum opinion, we use aliases to refer to minors. See generally 2

Tex. R. App. P. 9.9(a)(3).

The ISD Employees did not challenge the existence of jurisdictional evidence.

Waltons lacked standing to seek injunctive relief that infringes upon a third-party student’s right to attend school and school events. The Waltons filed a response, in which they contended that they were not required to exhaust their administrative remedies before filing suit because “[t]he immediate threats to [Paula’s] safety constitute irreparable harm that cannot adequately be addressed through administrative procedures.” They also argued that they had properly pleaded ultra vires claims against the ISD Employees, for which immunity is waived, because Education Code Section 37.115 “creates specific, non-discretionary duties regarding threat assessment and student safety that [the ISD Employees] allegedly failed to perform after being informed of threatening behavior.”

After a hearing at which the trial court considered the plea to the jurisdiction and the Waltons’ claim for declaratory relief, the trial court denied the ISD Employees’ plea to the jurisdiction and ordered the ISD Employees “to perform a threat assessment, no later than seven business days from the date of th[e] order, of each threat made by [David] during the 25-26 school year against [Paula] in compliance with Sanger Independent School District’s Threat Assessment Procedures.”4 The ISD Employees appealed. At the ISD Employees’ request, we stayed all trial court-proceedings while considering this appeal.

4 Attached to and incorporated into this order are two documents that do not appear anywhere else in the record: a document entitled “Threat Assessment Procedures” and a two-page flow chart detailing the threat assessment process. Both contain internal references to Sanger ISD.

III. DISCUSSION

Because it is dispositive,5 we first consider the ISD Employees’ contention that the Waltons did not plead sufficient facts showing a waiver of governmental immunity because they failed to plead a proper ultra vires claim. A. Standard of Review We review de novo a trial court’s jurisdictional ruling. Tex. Dep’t of Parks & Wildlife v. Miranda, 133 S.W.3d 217, 226 (Tex. 2004).

When a defendant challenges whether the plaintiff has alleged facts sufficient to waive immunity, as the ISD Employees have here, we liberally construe the pleadings in the plaintiff’s favor, considering all factual assertions to be true and looking to the plaintiff’s intent. Tex. Dep’t of Crim. Just. v. Rangel, 595 S.W.3d 198, 205 (Tex. 2020). Even under that liberal construction, the plaintiffs must demonstrate, through the facts alleged in their live pleading, that immunity from suit has been waived. Doe v. City of Fort Worth, 646 S.W.3d 889, 897 (Tex. App.—Fort Worth 2022, no pet.); see Walker Cnty. ESD No. 3 v. City of Huntsville, 658 S.W.3d 807, 816 (Tex. App.––Waco 2022, pet. denied) (explaining that court must apply facts alleged in pleadings to

5 A disposition in the ISD Employees’ favor on any of their issues would result in the same disposition: dismissal for want of jurisdiction. See, e.g., Image API, LLC v. Young, 691 S.W.3d 831, 836 n. 20 (Tex. 2024) (noting that proper remedy for improper ultra vires claim is dismissal for lack of jurisdiction); Clint Indep. Sch. Dist. v. Marquez, 487 S.W.3d 538, 545–46, 560 (Tex. 2016) (noting same for exhaustion of administrative remedies); Sealy RG Valley Bldgs., L.P. v. Griffin, No. 13-07-598-CV, 2008 WL 3906408, at *2 (Tex. App.—Corpus Christi–Edinburg Aug. 26, 2008, no pet.) (mem. op.) (holding same when relief not available under UDJA).

relevant statutory provisions to determine whether plaintiff pleaded ultra vires claim). Conclusory allegations alone will not suffice. See Casper v. Tex. Woman’s Univ., No. 02- 22-00345-CV, 2023 WL 5617129, at *14 (Tex. App.––Fort Worth Aug. 31, 2023, pet. denied) (mem. op.).

If the pleadings do not contain sufficient facts to affirmatively demonstrate the trial court’s jurisdiction but also do not affirmatively demonstrate incurable defects in jurisdiction, the issue is one of pleading sufficiency, and the plaintiff should be allowed to amend. Tex. A & M Univ. Sys. v. Koseoglu, 233 S.W.3d 835, 840 (Tex. 2007); Miranda, 133 S.W.3d at 226–27.

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Jill Morphis, Shila Borchert, Tommy Hunter, Jennie Flaa, and Mike Picha v. Justin Walton and Mariah Walton, A/N/F P.W., (Tex. Ct. App. 2026).

Jill Morphis, Shila Borchert, Tommy Hunter, Jennie Flaa, and Mike Picha v. Justin Walton and Mariah Walton, A/N/F P.W. (Jill Morphis, Shila Borchert, Tommy Hunter, Jennie Flaa, and Mike Picha v. Justin Walton and Mariah Walton, A/N/F P.W.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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