Olga Reyes and Daniela Bonilla v. Montgomery County

CourtCourt of Appeals of Texas
DecidedJuly 24, 2025
Docket09-25-00014-CV
StatusPublished

This text of Olga Reyes and Daniela Bonilla v. Montgomery County (Olga Reyes and Daniela Bonilla v. Montgomery County) 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
Olga Reyes and Daniela Bonilla v. Montgomery County, (Tex. Ct. App. 2025).

Opinion

In The

Court of Appeals

Ninth District of Texas at Beaumont

__________________

NO. 09-25-00014-CV __________________

OLGA REYES AND DANIELA BONILLA, Appellants

V.

MONTGOMERY COUNTY, Appellee

__________________________________________________________________

On Appeal from the 457th District Court Montgomery County, Texas Trial Cause No. 24-04-05132-CV __________________________________________________________________

MEMORANDUM OPINION

Appellants Olga Reyes and Daniela Bonilla (collectively “Appellants” or

“Plaintiffs”) sued Montgomery County (“Appellee” or “the County”) after a patrol

car driven by Brent Guidry, who was employed at the time of the accident by the

County as a patrol deputy, hit Appellants’ vehicle. The County filed a plea to the

jurisdiction, and the trial court granted the plea and dismissed the case with

prejudice. Appellants filed a motion for reconsideration and, in the alternative,

motion for new trial, which was overruled by operation of law. Appellants timely

1 filed this appeal. In two issues, Appellants argue the trial court erred in granting the

County’s plea to the jurisdiction and erred in failing to grant Plaintiffs’ motion for

reconsideration and, in the alternative, motion for new trial. See Tex. Civ. Prac. &

Rem. Code Ann. § 51.012; Tex. R. App. P. 26.1(a). We affirm the trial court’s

judgment.

Background

Plaintiffs filed a petition 1 alleging that on August 16, 2022, they were

traveling in a vehicle in Montgomery County when Brent Guidry drove his vehicle

into the rear of their vehicle. Plaintiffs alleged that Guidry “was acting within the

course and scope of his employment with Montgomery County when he was

following too closely and not maintaining a proper lookout or paying attention as an

ordinary, prudent individual would have in the same or similar situation.” According

to the petition, Defendant Guidry’s negligence was the proximate cause of Plaintiffs’

injuries and damages. The petition also asserted that Defendant Montgomery County

was liable for Guidry’s acts and omissions under the doctrines of agency and

respondeat superior. Plaintiffs filed Plaintiffs’ First Amended Notice of Partial Non-

Suit, requesting the trial court non-suit Plaintiffs’ claims against Guidry, and the trial

court signed an Order Granting Nonsuit and dismissed the claims against Guidry

1 We refer to Plaintiffs’ Second Amended Petition, the petition on file at the time the trial court granted the County’s plea to the jurisdiction, as the “petition.” 2 without prejudice. The County filed an Answer denying Plaintiffs’ allegations,

including Plaintiffs’ allegation that Guidry was acting within the course and scope

of his employment at the time of the accident, and the County asserted “the

affirmative defense of sovereign/governmental immunity, including but not limited

to, the application of the Texas Tort Claims Act and limitations of damages.”

The County filed Defendant’s Plea to the Jurisdiction, arguing that

(1) Plaintiffs failed to plead and prove a valid waiver of immunity and claim against

the County, and (2) Plaintiffs’ claims against the County are barred by immunity and

do not fall under the Texas Tort Claims Act (“TTCA”) because Guidry was not

acting within the course and scope of his employment at the time of the accident. In

support of the plea, the County attached as exhibits: the Texas Peace Officer’s Crash

Report from the accident; Guidry’s typewritten “24-HOUR activities summary[]”

summarizing the accident and events just before and after the accident that he

provided to Sergeant Layman and Sergeant Lowery; and Sergeant Cody Lowery’s

affidavit with attached exhibits including a timesheet for Guidry on the day of the

accident, Guidry’s typewritten “24-HOUR activities summary[,]” and certain

Montgomery County Sheriff’s Office (“MCSO”) policies.

Plaintiffs filed Plaintiffs’ Response to Defendant’s Plea to the Jurisdiction,

arguing that the County’s immunity from Plaintiffs’ claims is waived by the TTCA

because, under Texas law, peace officers are never off duty, so the County is liable

3 for Deputy Guidry’s actions while operating his patrol car; that Guidry had testified

during his deposition that he was on duty and acting within his scope of employment

at the time of the accident; and that the County had not met its burden to present

evidence showing that Guidry was off duty at the time of the accident and that the

County’s immunity was waived under the TTCA.

The trial court granted the County’s plea to the jurisdiction. Plaintiffs filed

Plaintiffs’ Motion for Reconsideration Granting of Defendant’s Plea to the

Jurisdiction or, in the Alternative, Motion for New Trial. In the motion, Plaintiffs

argued that, according to Guidry’s deposition transcript, which was not attached to

the response to the plea because Plaintiffs alleged it was unavailable, Guidry testified

that he was on duty at the time of the accident “per [the County’s] policy[]” and that

he was on duty until he pulled into his driveway of his home at the end of his shift.

Plaintiffs argued that Guidry’s testimony, along with Deputy Guidry’s timesheet

which shows no gaps in the time he worked on the day of the wreck, raise a fact

issue about whether Guidry was on duty at the time of the accident. The motion was

overruled by operation of law. Plaintiffs timely appealed.

Standard of Review and Applicable Law

Governmental immunity protects political subdivisions, including counties,

from lawsuits for damages, because unless the governmental unit has consented to

suit, a trial court lacks subject matter jurisdiction to consider a claim against it. See

4 Tex. Dep’t of Parks & Wildlife v. Miranda, 133 S.W.3d 217, 224 (Tex. 2004);

Wichita Falls State Hosp. v. Taylor, 106 S.W.3d 692, 696 (Tex. 2003); see also Tex.

Civ. Prac. & Rem. Code Ann. § 101.001(3)(B). Consent to suit is found in a

constitutional or legislative provision, and whether subject matter jurisdiction exists,

based on a waiver of immunity, is a question of law; we therefore review the trial

court’s ruling on a plea to the jurisdiction de novo. State v. Holland, 221 S.W.3d

639, 642 (Tex. 2007); Miranda, 133 S.W.3d at 226.

A plea to the jurisdiction may challenge either the sufficiency of the

jurisdictional allegations in the pleadings or the existence of jurisdictional facts.

Miranda, 133 S.W.3d at 226-27. A governmental entity may file a plea to the

jurisdiction to challenge a court’s power to resolve the merits of a plaintiff’s claims.

See Bland Indep. Sch. Dist. v. Blue, 34 S.W.3d 547, 554 (Tex. 2000). To defeat the

governmental immunity claim, the plaintiff must plead facts that affirmatively

demonstrate that governmental immunity has been waived and the trial court has

subject matter jurisdiction. See Holland, 221 S.W.3d at 642; Dall. Area Rapid

Transit v. Whitley, 104 S.W.3d 540, 542 (Tex. 2003); Tex. Ass’n of Bus. v. Tex. Air

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