Ricardo Garza v. Mike Morath, Texas Commissioner of Education and La Joya Independent School District

CourtCourt of Appeals of Texas
DecidedDecember 19, 2024
Docket13-23-00257-CV
StatusPublished

This text of Ricardo Garza v. Mike Morath, Texas Commissioner of Education and La Joya Independent School District (Ricardo Garza v. Mike Morath, Texas Commissioner of Education and La Joya Independent School District) 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
Ricardo Garza v. Mike Morath, Texas Commissioner of Education and La Joya Independent School District, (Tex. Ct. App. 2024).

Opinion

NUMBER 13-23-00257-CV

COURT OF APPEALS

THIRTEENTH DISTRICT OF TEXAS

CORPUS CHRISTI – EDINBURG

RICARDO GARZA, Appellant,

v.

MIKE MORATH, TEXAS COMMISSIONER OF EDUCATION AND LA JOYA INDEPENDENT SCHOOL DISTRICT, Appellees.

ON APPEAL FROM THE 430TH DISTRICT COURT OF HIDALGO COUNTY, TEXAS

MEMORANDUM OPINION Before Justices Longoria, Tijerina, and Peña Memorandum Opinion by Justice Tijerina

This appeal stems from the nonrenewal of appellant Ricardo Garza’s employment

contract with appellee La Joya Independent School District (the District). Garza appeals

the trial court’s decision upholding appellee the Texas Commissioner of Education’s (Commissioner) decision denying Garza’s appeal of the District’s nonrenewal. By two

issues, Garza argues: (1) the District did not conduct its own investigation and instead

accepted the investigation performed by its police department; and (2) substantial

evidence does not support the Commissioner’s decision. We affirm.

I. BACKGROUND

The District employed Garza as a physical education elementary school teacher

under a term contract. See TEX. EDUC. CODE ANN. § 21.201(3) (defining “term contract”

as “any contract of employment for a fixed term between a school district and a teacher”).

After three second-grade students accused Garza of inappropriately touching them,

Garza was placed on administrative leave with pay on January 22, 2022. Garza was

subsequently arrested for the allegations.

On May 11, 2022, the District sent Garza notice of its proposed nonrenewal. Garza

requested a hearing before the school board pursuant to the District’s nonrenewal

policies. See id. § 21.207(a) (requiring the school board to provide a hearing within fifteen

days of the teacher’s request after notice of a proposed nonrenewal). A hearing was held

on June 14, 2022. Witnesses testified on the District’s behalf including its superintendent,

several of Garza’s colleagues, parents, and Garza’s principal. Garza was present at the

hearing with his attorney, and evidence was presented. Following the hearing, the school

board voted to uphold the District’s recommendation that Garza’s contract not be

renewed. The District notified Garza that it would not be renewing his contract based on

these specific provisions of the District’s policy: failure to fulfill duties or responsibilities,

2 insubordination, failure to meet professional conduct, diminished capacity of

effectiveness because of publicity, breach of contract, behavior that presents a physical

harm to students, assault on a student, and good cause.

Garza appealed the school board’s decision to the Commissioner on June 30,

2022. See id. § 21.301 (“Appeal to Commissioner”). On August 17, 2022, the

Commissioner issued a written decision, affirming the school board’s vote. Garza then

appealed to the district court. See id. § 21.307 (“Judicial Appeals”). After reviewing the

merits of Garza’s appeal, the district court affirmed the Commissioner’s decision, finding

that the denial of Garza’s appeal was supported by substantial evidence. This appeal

followed.

II. SUBSTANTIAL EVIDENCE

By two issues, Garza argues that the District’s decision not to renew his contract

is not supported by substantial evidence because the District solely relied on its police

department’s investigation rather than conduct its own independent investigation.

A. Standard of Review & Applicable Law

An aggrieved party may appeal a school board’s decision not to renew a term

contract to the Commissioner. See id. § 21.301. In reviewing the school board’s decision,

the Commissioner may not substitute his or her judgment for that of the school board

unless the school board’s decision is: (1) arbitrary, capricious, or unlawful; or (2) not

supported by substantial evidence. Id. § 21.303(b)(1). The Commissioner may not

reverse a decision of a school board based on a procedural irregularity or error by the

3 board unless the Commissioner determines that the irregularity or error was likely to have

led to an erroneous decision. Id. § 21.303(c). The Commissioner must also issue a written

decision that includes findings of fact and conclusions of law. See id. § 21.304.

A party may appeal the Commissioner’s decision to the district court. See

id. § 21.307 (a)(1) (providing for judicial review of the commissioner’s decision). Under

the substantial evidence rule, the district court “review[s] the evidence on the evidentiary

record made at the local level and any evidence taken by the commissioner but may not

take additional evidence.” Id. § 21.307(e). The district court may not “reverse the decision

of the commissioner unless the decision was not supported by substantial evidence or

unless the commissioner’s conclusions of law are erroneous.” Id. § 21.307(f). “Substantial

evidence review is a limited standard of review, requiring ‘only more than a mere scintilla

[of evidence],’ to support an agency’s determination.” Edinburg Consol. Indep. Sch. Dist.

v. Esparza, 603 S.W.3d 468, 478 (Tex. App.—Corpus Christi–Edinburg 2020, no pet.)

(quoting Montgomery Indep. Sch. Dist. v. Davis, 34 S.W.3d 559, 562 (Tex. 2000)).

In our review, we “focus on whose decision is properly before us.” Davis, 34

S.W.3d at 562. “If, based on the evidence as a whole, reasonable minds could have

reached the same conclusion as the Commissioner, then the Commissioner’s decision is

supported by substantial evidence.” Id. Whether the Commissioner’s decision is

supported by substantial evidence is a question of law. Id. “[E]vidence in the record may

preponderate against the agency decision and still amount to substantial evidence

4 supporting the decision,” and we will “uphold the Commissioner’s decision on any legal

basis shown in the record.” Id.

B. Discussion

Garza argues that the only evidence before the District was its police department’s

investigation and that the District is prohibited from using this evidence to make an

administrative decision. Contrary to Garza’s assertion, this record is replete with evidence

the Commissioner considered in its review of Garza’s appeal including: walkthrough

evaluations performed by Garza’s principal Dulce Diaz and assistant principal Yvonne

Rosales wherein they observed his interactions with female students and lack of

classroom management; communication logs between Diaz, Garza, and Rosales

instructing Garza to redirect his behavior and keep his distance from female students;

affidavits from Garza’s colleagues witnessing his physical interactions and inappropriate

physical contact with female students; conference notes between Diaz and Garza

regarding student safety; affidavits from parents of the children who made outcries

regarding Garza inappropriately touching the female students; numerous student

interviews; forensic interviews of the alleged child victims; the District’s police department

investigation report; the District’s employee handbook; the District’s local policies;

evidence that Garza received sexual harassment training; warrants for Garza’s arrest;

questionnaires from Garza’s colleagues; and the Title IX Investigator report, among

others.

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Related

Peaster Independent School District v. Glodfelty
63 S.W.3d 1 (Court of Appeals of Texas, 2001)
Montgomery Independent School District v. Davis
34 S.W.3d 559 (Texas Supreme Court, 2000)
Tarrant v. Clear Creek Independent School District
238 S.W.3d 445 (Court of Appeals of Texas, 2007)

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Ricardo Garza v. Mike Morath, Texas Commissioner of Education and La Joya Independent School District, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ricardo-garza-v-mike-morath-texas-commissioner-of-education-and-la-joya-texapp-2024.