Mike Morath, in His Official Capacity as Texas Commissioner of Education and La Villa Independent School District v. Dr. Paz Elizondo

Court of Appeals of Texas·Decided May 5, 2025·No. 15-25-00024-CV·Published

Opinion

ACCEPTED 15-25-00024-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 5/5/2025 9:48 PM No. 15-25-00024-CV CHRISTOPHER A. PRINE CLERK _______________________________________________________________ FILED IN 15th COURT OF APPEALS AUSTIN, TEXAS IN THE FIFTEENTH COURT OF APPEALS 5/5/2025 9:48:56 PM OF TEXAS CHRISTOPHER A. PRINE _______________________________________________________________ Clerk

Mike Morath, Texas Commissioner of Education and La Villa Independent School District Appellants v.

Dr. Paz Elizondo Appellee _______________________________________________________________

Appeal from the 455th District Court of Travis County, Texas, Cause No. D-1-GN-22-002025 _______________________________________________________________

La Villa Independent School District’s Reply Brief _______________________________________________________________

David J. Campbell dcampbell@808west.com State Bar No. 24057033 THOMPSON & HORTON LLP 8300 N. MoPac Expressway, Suite 220 Austin, Texas 78759 (512) 825-3114 (713) 583-8884 (fax)

Appellant La Villa ISD TABLE OF CONTENTS Page

TABLE OF CONTENTS ........................................................................... 2

INDEX OF AUTHORITIES ...................................................................... 4

ISSUES PRESENTED .............................................................................. 5

INTRODUCTION ...................................................................................... 6

ARGUMENT ............................................................................................. 8

I. The trial court erred in reversing the Commissioner’s Decision......................................................... 8

A. School districts are authorized to dismiss grievances as untimely. ................................................. 8

B. The Commissioner’s Decision appropriately affirmed the school district’s dismissal of the grievance as untimely. ................................................. 10

C. The Commissioner’s Decision does not conflict with past Commissioner decisions. ................. 12

D. The Commissioner’s Decision appropriately recognizes that the triggering event for Dr. Elizondo’s grievance was his receipt of the probationary contract .................................................. 14

E. The Court could address this entire case based on waiver because the Commissioner’s decision was based, in the alternative, on waiver. .......................................................................... 17

II. Dr. Elizondo asks this Court to affirm the trial court’s judgment on his declaratory judgment claim even though the trial court dismissed. ....................... 19

2 PRAYER .................................................................................................. 21

CERTIFICATE OF COMPLIANCE ........................................................ 23

CERTIFICATE OF SERVICE................................................................. 23

3 INDEX OF AUTHORITIES Page Cases

Bella Palma, LLC v. Young, 601 S.W.3d 799 (Tex. 2020) ................................................................. 20

Davis v. Morath, 624 S.W.3d 215 (Tex. 2021) ........................................................ passim

Lehmann v. Har-Con Corp., 39 S.W.3d 191 (Tex. 2001) ................................................................... 20

Morath v. Elizondo, No. 03-23-00125-CV, 2025 WL 270611 (Tex. App.—Austin Jan. 23, 2025, no pet.) ......................................................................... 20

Statutes

Tex. Educ. Code § 11.1511(b)(13) .............................................................. 9 Tex. Educ. Code § 21.103 .................................................................. 16, 19 Tex. Educ. Code § 21.1041 ...................................................................... 16 Tex. Educ. Code § 21.207 ........................................................................ 16 Tex. Educ. Code §§ 21.251–.259 .............................................................. 19

Other Authorities

Higareda v. Valley View Ind. Sch. Dist., No. 027-R10-12-2013 (Tex. Comm’r Educ. Oct. 7, 2014) ............... 12, 13

Rules

Tex. R. App. P. 25.1 ................................................................................. 21

4 ISSUES PRESENTED The Court should disregard Dr. Elizondo’s second issue because it is

based on the mistaken impression that the trial court found his

declaratory judgment claim “was sustainable.” Appellee’s Br. at 5. The

opposite is true. The trial court dismissed that claim. See Appx 450.

5 INTRODUCTION Throughout his brief, Dr. Elizondo repeatedly complains it is unfair

that his grievance was dismissed as untimely because he should win on

the merits of his complaint. Before the merits of his grievance could be

addressed, Dr. Elizondo had the burden to establish that his grievance

was timely. See, e.g., Davis v. Morath, 624 S.W.3d 215, 223 (Tex. 2021).

In this case, it was not. And that should resolve this entire case.

La Villa ISD denied Dr. Elizondo’s complaint because it was

untimely—filed over a year after the fact. Compare Appx 185–88 with

Appx 190. So La Villa ISD did not need to consider the merits of

Dr. Elizondo’s claim one way or the other because regardless of the merits

the complaint was clearly untimely. Appx 117–18.

The Commissioner affirmed that untimeliness decision. In the appeal

to the Commissioner, the merits of Dr. Elizondo’s claim were irrelevant

because the only question before the Commissioner was whether Dr.

Elizondo’s complaint was properly dismissed as untimely. Appx 262–67;

see also Davis, 624 S.W.3d at 223 (explaining that the Commissioner of

Education is not authorized to “reach the merits of a complainant’s

arguments” if the underlying grievance “was not timely brought at the

6 District level”).

The local grievance policy in La Villa ISD (and in school districts

across the State) does not “nullify the clear dictates of the Texas

Legislature,” as Dr. Elizondo asserts on page 6 of his brief. Rather, the

grievance policy provides an opportunity for a grievance to be heard and

resolved if it is filed within 15 days of when the employee “first knew, or

with reasonable diligence should have known, of the action giving rise to

the complaint or grievance.” Appx 118. If Dr. Elizondo had complained

about the type of contract he was given at the beginning of the school year,

La Villa ISD could have considered the complaint and if it had any merit,

the school district could have provided a remedy by giving him a different

type of contract. But at the end of the school year, it was too late for

La Villa ISD to provide any remedy based on the complaint Dr. Elizondo

filed.

7 ARGUMENT I. The trial court erred in reversing the Commissioner’s Decision.

In its opening brief, La Villa ISD explained that the trial court erred

in reversing the Commissioner’s Decision because there is evidence in the

administrative record that Dr.

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Mike Morath, in His Official Capacity as Texas Commissioner of Education and La Villa Independent School District v. Dr. Paz Elizondo, (Tex. Ct. App. 2025).

Mike Morath, in His Official Capacity as Texas Commissioner of Education and La Villa Independent School District v. Dr. Paz Elizondo (Mike Morath, in His Official Capacity as Texas Commissioner of Education and La Villa Independent School District v. Dr. Paz Elizondo) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Lehmann v. Har-Con Corp.
39 S.W.3d 191 (Texas Supreme Court, 2001)