Olympic Waste Services, a Division of Allied Waste Industries, Inc. v. the City of Grand Saline, Texas

CourtCourt of Appeals of Texas
DecidedSeptember 29, 2006
Docket12-05-00217-CV
StatusPublished

This text of Olympic Waste Services, a Division of Allied Waste Industries, Inc. v. the City of Grand Saline, Texas (Olympic Waste Services, a Division of Allied Waste Industries, Inc. v. the City of Grand Saline, 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.

Bluebook
Olympic Waste Services, a Division of Allied Waste Industries, Inc. v. the City of Grand Saline, Texas, (Tex. Ct. App. 2006).

Opinion

                NO. 12-05-00217-CV

IN THE COURT OF APPEALS

TWELFTH COURT OF APPEALS DISTRICT

TYLER, TEXAS

OLYMPIC WASTE SERVICES,

A DIVISION OF ALLIED WASTE

INDUSTRIES, INC.,            §          APPEAL FROM THE 294TH

APPELLANT

V.        §          JUDICIAL DISTRICT COURT OF

THE CITY OF GRAND SALINE, TEXAS,

APPELLEE                                                        §     VAN ZANDT COUNTY, TEXAS


OPINION


            Olympic Waste Services, a division of Allied Waste Industries, Inc., appeals from the trial court’s orders granting the City of Grand Saline’s plea to the jurisdiction and motion for summary judgment and the trial court’s order denying Olympic’s motion for partial summary judgment.  In five issues, Olympic contends the City is not immune from suit for breach of contract and the trial court made erroneous rulings regarding its claim for violations of the Texas Open Meetings Act.1  We  affirm in part and reverse and render in part.

Background


            Beginning in February 1989, Olympic contracted with the City to provide solid waste removal services.  The contract had an initial five year term and renewed automatically for successive five year terms.  However, either party could terminate with notice at least sixty days prior to the end of the five year term.  On February 10, 2004, the Grand Saline city council awarded a “garbage contract” to Easley Sanitation, to be effective April 1, 2004.  Olympic received a letter from the City dated February 17, 2004, stating that its contract with the City was “breached and terminated” on the grounds that Olympic had failed to provide certificates of insurance and surety bonds.  The letter stated that Olympic would no longer receive payment from the City.

            Olympic filed suit to have the contract between Easley and the City declared void due to violations of the Texas Open Meetings Act and the Local Government Code’s competitive bidding requirements and to have the contract between Olympic and the City declared to be in full force.  Alternatively, Olympic asserted a cause of action against the City for breach of contract.  Olympic also alleged that Easley committed tortious interference with its contract with the City and conspired with unknown others to interfere with Olympic’s contractual relations with the City.

            Claiming immunity to suit, the City filed a plea to the jurisdiction arguing that the trial court did not have jurisdiction over Olympic’s causes of action based on its contract with the City, that is, the request for declaratory judgment on the contract termination and the breach of contract claim.  The City filed a motion for summary judgment on the cause of action for violation of competitive bidding, relying on an exception to the statute, and on the cause of action for violations of the Open Meetings Act based on statutory authority to consult with the city attorney in executive session.  Olympic filed a partial motion for summary judgment addressing the alleged open meetings violations.  The trial court denied Olympic’s motion and granted the City’s plea to the jurisdiction and its motion for summary judgment.  Later, Olympic nonsuited Easley, dropping its tortious interference and conspiracy claims.

Plea to the Jurisdiction

            In its first issue, Olympic contends the trial court erred in granting the City’s plea to the jurisdiction.  Relying on the Local Government Code, which states that a municipality may sue and be sued, it argues that the City is subject to a legislative waiver of immunity for its contract claim.

Standard of Review

            Immunity from suit bars an action against the State unless the State expressly consents to the suit.  Texas Dep’t of Transp. v. Jones, 8 S.W.3d 636, 638 (Tex. 1999).  Since as early as 1847, the law in Texas has been that absent the State’s consent to suit, a trial court lacks subject matter jurisdiction.  Id.  The absence of subject matter jurisdiction may be raised by a plea to the jurisdiction.  Bland Indep. Sch. Dist. v. Blue, 34 S.W.3d 547, 554 (Tex. 2000).  Because subject matter jurisdiction presents a question of law, we review the trial court’s decision to grant a plea to the jurisdiction de novo.  Mayhew v. Town of Sunnyvale, 964 S.W.2d 922, 928 (Tex. 1998).        In reviewing a plea to the jurisdiction, we review the pleadings and any evidence relevant to the jurisdictional issue.  Texas Dep’t of Crim. Justice v. Miller, 51 S.W.3d 583, 587 (Tex. 2001).  The party suing the governmental entity must establish the State’s consent, which may be alleged either by reference to a statute or to express legislative permission.  Jones, 8 S.W.3d at 638.  In considering the jurisdictional allegations contained in a petition, they are to be construed liberally in the plaintiff’s favor.  Texas Ass’n of Bus. v. Texas Air Control Bd., 852 S.W.2d 440, 446 (Tex. 1993).

Discussion

           

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Olympic Waste Services, a Division of Allied Waste Industries, Inc. v. the City of Grand Saline, Texas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/olympic-waste-services-a-division-of-allied-waste--texapp-2006.