Leon County, Texas v. Frances Donahoe

CourtCourt of Appeals of Texas
DecidedFebruary 10, 2010
Docket10-09-00010-CV
StatusPublished

This text of Leon County, Texas v. Frances Donahoe (Leon County, Texas v. Frances Donahoe) 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
Leon County, Texas v. Frances Donahoe, (Tex. Ct. App. 2010).

Opinion

IN THE TENTH COURT OF APPEALS

No. 10-09-00010-CV

LEON COUNTY, TEXAS, Appellant v.

FRANCES DONAHOE, Appellee

From the 12th District Court Leon County, Texas Trial Court No. PI-06-378

MEMORANDUM OPINION

Frances Donahoe sued Leon County for personal injuries, asserting a premises

liability claim. Leon County filed a plea to the jurisdiction and special exceptions, and

Donahoe filed an amended petition. After some discovery had taken place, Leon

County filed a “motion to dismiss for lack of subject-matter jurisdiction and,

alternatively, for summary judgment.” The trial court denied the plea to the

jurisdiction and the motions for summary judgment. Asserting three issues, Leon

County appeals. We will affirm. A county’s immunity from suit defeats a trial court’s subject matter jurisdiction;

thus, it is properly asserted in a plea to the jurisdiction. See Tex. Dep’t of Parks & Wildlife

v. Miranda, 133 S.W.3d 217, 225-26 (Tex. 2004). Whether the trial court had subject

matter jurisdiction is a question of law that we review de novo. Tex. Natural Res.

Conservation Comm’n v. IT-Davy, 74 S.W.3d 849, 855 (Tex. 2002).

Leon County’s first issue asserts that the trial court erred in denying the plea to

the jurisdiction on the ground that Donahoe’s pleadings were insufficient to invoke the

trial court’s jurisdiction.

When reviewing whether a plea was properly granted [or denied], we first look to the pleadings to determine if jurisdiction is proper, construing them liberally in favor of the plaintiffs and looking to the pleader's intent. The allegations found in the pleadings may either affirmatively demonstrate or negate the court’s jurisdiction.

City of Waco v. Kirwan, --- S.W.3d ---, ---, 2009 WL 3969375, at *2 (Tex. Nov. 20, 2009)

(citations omitted). The plaintiff has the burden of alleging facts that affirmatively

establish the trial court’s subject matter jurisdiction. Tex. Ass’n of Bus. v. Tex. Air Control

Bd., 852 S.W.2d 440, 446 (Tex. 1993). We accept the pleading’s factual allegations as

true. Miranda, 133 S.W.3d at 226.

Donahoe’s amended petition states:

This cause of action is brought under and pursuant to what is commonly known as the Texas Tort Claims Act and in particular is brought pursuant and subject to § 101.021 dealing with Governmental Liability for premises and special defects. Your Plaintiff would show unto the Court and jury that on or about the 2nd day of June, 2006, at or about the hour of 11:00 o’clock a.m., she had gone to Centerville, Leon County, Texas, to the courthouse in order to pay her taxes, and while in Leon County and upon the premises owned, claimed and maintained by Leon County at the Centerville Courthouse, the County Seat of Leon County,

Leon County v. Donahoe Page 2 Ms. Donahoe, while walking upon the sidewalk was caused to slip and fall or trip and fall upon an uneven and unlevel surface that created and constitutes a special defect or premises defect as those terms are known and understood at law. The walkway that had been laid by whatever person or entity was improperly and defectively done and obscured and covered with a mat causing Ms. Donahoe to trip and fall and injure herself causing her to break both of her wrists and causing significant soft tissue injury to her hands and arms, as well as, an injury to her right shoulder.

Your Plaintiff would show that Leon County, Texas, and its agents, servants and employees created a dangerous and unsafe condition for people using the premises, and rather than make the premises safe or to warn of the unsafe conditions, it tried to cover the unlevel area with mats. No warning signs were placed, the area was not roped off, and there was no attempt to warn the public of the existence of the condition. The condition was well-known to the County officials but totally and completely unknown to Frances Donahoe. If it be found that the condition created was not a special defect then alternatively the Plaintiff pleads that the premises in question was a premises defect as that term is know and understood at law.1

Section 101.025 of the Texas Tort Claims Act provides for a waiver of sovereign

immunity to the extent of liability created by the Act and allows a person having a

claim under the Act to sue a governmental unit for damages as allowed by the Act. TEX.

CIV. PRAC. & REM. ANN. § 101.025 (Vernon 2005). “A governmental unit in the state is

liable for: … (2) personal injury and death so caused by a condition or use of tangible

personal or real property if the governmental unit would, were it a private person, be

liable to the claimant according to Texas law.” Id. § 101.021(2) (Vernon 2005).

Subsection 101.022(a) provides that “if a claim arises from a premise defect, the

governmental unit owes to the claimant only the duty that a private person owes to a

licensee on private property, unless the claimant pays for the use of the premises.” Id. §

1Donahoe abandoned her special defect allegation and seeks recovery only for an ordinary premises defect as a licensee.

Leon County v. Donahoe Page 3 101.022(a) (Vernon Supp. 2009). “Thus, a governmental unit may be liable for an

ordinary premises defect only if a private person would be liable to a licensee under the

same circumstances.” County of Cameron v. Brown, 80 S.W.3d 549, 554 (Tex. 2002).

The elements of a licensee’s premises liability claim are:

a condition of the premises created an unreasonable risk of harm to the licensee;

the owner actually knew of the condition;

the licensee did not actually know of the condition;

the owner failed to exercise ordinary care to protect the licensee from danger either by not adequately warning the licensee of the condition or by not making the condition reasonably safe; and

the owner’s failure was a proximate cause of injury to the licensee.

Id.; State Dep’t of Hwys. & Pub. Transp. v. Payne, 838 S.W.2d 235, 237 (Tex. 1992).

Leon County contends that Donahoe’s pleading are insufficient because they: (1)

fail to allege any facts to support the allegation that the condition was unreasonably

dangerous; (2) fail to identify the “responsible county official” who had actual

knowledge of the condition; and (3) fail to allege that a “responsible county official” had

actual knowledge of an unreasonable risk of harm posed by the condition.

We find that Donahoe has sufficiently pled the elements of an ordinary premises

defect claim against Leon County to invoke the trial court’s subject matter jurisdiction.

First, she pled that her suit is brought under the Texas Tort Claims Act and pled the

relevant section of the Act. See Tex. Dep’t Transp. v. Jones, 8 S.W.3d 636, 638 (Tex. 1999)

(“The party suing the governmental entity must establish the state’s consent, which

Leon County v. Donahoe Page 4 may be alleged either by reference to a statute or to express legislative permission.”); see

also Tex. Dep’t Crim. Just. v.

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