Phil Bellamy v. the City of Brownsville and City Manager, Noel Bernal

CourtCourt of Appeals of Texas
DecidedJanuary 26, 2023
Docket13-22-00087-CV
StatusPublished

This text of Phil Bellamy v. the City of Brownsville and City Manager, Noel Bernal (Phil Bellamy v. the City of Brownsville and City Manager, Noel Bernal) 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
Phil Bellamy v. the City of Brownsville and City Manager, Noel Bernal, (Tex. Ct. App. 2023).

Opinion

NUMBER 13-22-00087-CV

COURT OF APPEALS

THIRTEENTH DISTRICT OF TEXAS

CORPUS CHRISTI – EDINBURG

PHIL BELLAMY, Appellant,

v.

CITY OF BROWNSVILLE AND CITY MANAGER, NOEL BERNAL, Appellees.

On appeal from the 107th District Court of Cameron County, Texas.

MEMORANDUM OPINION

Before Justices Benavides, Tijerina, and Peña Memorandum Opinion by Justice Benavides

This is an interlocutory appeal from the denial of a temporary injunction. Appellees

City of Brownsville and City Manager Noel Bernal (collectively, the “City”) notified

appellant Phil Bellamy that he would not be reappointed as a municipal judge, and Bellamy filed suit against the City seeking a declaration that he was reappointed to

another term of office as a matter of law because the City’s notice was untimely. See TEX.

GOV’T CODE ANN. § 29.005 (“A municipal court judge who is not reappointed by the 91st

day following the expiration of a term of office shall, absent action by the appointing

authority, continue to serve for another term of office beginning on the date the previous

term of office expired.”). The parties dispute when Bellamy’s previous term expired, thus

triggering the City’s ninety-day window to act. See id.

The trial court granted Bellamy an ex parte temporary restraining order prohibiting

his removal from office, but after conducting a hearing and receiving evidence, the court

denied Bellamy’s request to extend the injunction through trial. In what we construe as a

single issue, Bellamy argues that the trial court abused its discretion because he

demonstrated his entitlement to a temporary injunction. The City responds that Bellamy

failed to show a probable right to relief and that he would suffer irreparable harm without

an injunction. We affirm.

I. BACKGROUND

The historical facts in this case are undisputed. On October 31, 2005, the City

appointed Bellamy to serve his first term as a municipal judge. His term of office was for

two years and became effective November 2, 2005. From 2007 until 2017, the City

reappointed Bellamy to six successive two-year terms, always with an effective date of

November 2.

After his 2017–2019 term expired on November 2, 2019, the City notified Bellamy

in writing, on December 2, 2019, that he was being reappointed to another “two[-]year

2 term, effective December 2, 2019.” Bellamy accepted the appointment and took his oath

of office on December 9, 2019.

On November 2, 2021, Bellamy sent the City the following written correspondence:

“My term of office as an associate municipal judge expires on or about December 2, 2021.

I request that you renew my appointment. Please contact me if you would like to discuss

anything. Thank you.” On February 17, 2022, the City informed Bellamy that he would not

be reappointed for another term.

Bellamy filed suit the next day, seeking a temporary restraining order, temporary

injunction, and ultimately a declaration that he was reappointed to another term of office

as a matter of law. During the temporary injunction hearing, Bellamy testified that both

parties were mistaken about when his previous term commenced. According to Bellamy,

as a matter of law, his last term of office began on the date his previous term expired.

Thus, his term of office was from November 2, 2019, until November 2, 2021, and the

City’s notice was untimely.

The City countered that, irrespective of his previous terms of office, Bellamy’s last

term commenced on the date the City reappointed him. Consequently, his term of office

was from December 2, 2019, until December 2, 2021, and the City’s notice was timely.

The trial court denied Bellamy’s request for a temporary injunction, and this

interlocutory appeal ensued. See TEX. CIV. PRAC. & REM. CODE ANN. § 54.014(a)(4).

II. TEMPORARY INJUNCTIONS

The purpose of a temporary injunction “is to preserve the status quo of the

litigation’s subject matter” during the pendency of the case. Butnaru v. Ford Motor Co.,

3 84 S.W.3d 198, 204 (Tex. 2002) (citing Walling v. Metcalfe, 863 S.W.2d 56, 57 (Tex.

1993)). “A temporary injunction is an extraordinary remedy and does not issue as a matter

of right.” Id. (citing Walling, 863 S.W.2d at 57). To establish entitlement to a temporary

injunction, the plaintiff must “plead and prove three specific elements: (1) a cause of action

against the defendant; (2) a probable right to the relief sought; and (3) a probable,

imminent, and irreparable injury in the interim.” Id. (first citing Walling, 863 S.W.2d at 57;

and then citing Sun Oil Co. v. Whitaker, 424 S.W.2d 216, 218 (Tex. 1968)); see State v.

Hollins, 620 S.W.3d 400, 405 (Tex. 2020).

To establish a probable right to relief, the plaintiff is not required to prove that he

will prevail at trial; instead, he is only required to allege a cause of action and present

evidence tending to sustain the claim. Savering v. City of Mansfield, 505 S.W.3d 33, 39

(Tex. App.—Fort Worth 2016, pet. denied) (first citing Oil Field Haulers Ass’n v. R.R.

Comm’n, 381 S.W.2d 183, 196 (Tex. 1964), and then citing Frequent Flyer Depot, Inc. v.

Am. Airlines, Inc., 281 S.W.3d 215, 220 (Tex. App.—Fort Worth 2009, pet. denied)). “An

injury is irreparable if the injured party cannot be adequately compensated in damages

or if the damages cannot be measured by any certain pecuniary standard.” Butnaru, 84

S.W.3d at 204 (citing Canteen Corp. v. Republic of Tex. Props., Inc., 773 S.W.2d 398,

401 (Tex. App.—Dallas 1989, no writ)); see Pike v. Tex. EMC Mgmt., LLC, 610 S.W.3d

763, 792 (Tex. 2020). “[T]he requirement of demonstrating an [irreparable] injury is not to

be taken lightly.” Walling, 863 S.W.2d at 57.

We review a trial court’s denial of a temporary injunction for an abuse of discretion.

Butnaru, 84 S.W.3d at 204 (citing Walling, 863 S.W.2d at 58). A trial court abuses its

4 discretion if it acts “unreasonably or in an arbitrary manner, without reference to guiding

rules or principles.” Id. at 211 (citing Beaumont Bank v. Buller, 806 S.W.2d 223, 226 (Tex.

1991)). In conducting our review, we generally defer to the trial court’s judgment and view

the evidence in the light most favorable to the trial court’s decision. Allied Cap. Corp. v.

Cravens, 67 S.W.3d 486, 489 (Tex. App.—Corpus Christi–Edinburg 2002, no pet.) (first

citing Davis v. Huey, 571 S.W.2d 859, 861–62 (Tex. 1978); and then citing Rugen v.

Interactive Bus. Sys., Inc., 864 S.W.2d 548, 551 (Tex. App.—Dallas 1993, no writ)). “The

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