Robert C. Pruett v. City of Galena Park

CourtCourt of Appeals of Texas
DecidedJuly 12, 2022
Docket01-20-00521-CV
StatusPublished

This text of Robert C. Pruett v. City of Galena Park (Robert C. Pruett v. City of Galena Park) 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
Robert C. Pruett v. City of Galena Park, (Tex. Ct. App. 2022).

Opinion

Opinion issued July 12, 2022

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-20-00521-CV ——————————— ROBERT C. PRUETT, Appellant V. CITY OF GALENA PARK, Appellee

On Appeal from the 127th District Court Harris County, Texas Trial Court Case No. 2016-35876

MEMORANDUM OPINION

Appellant Robert C. Pruett was a long-time employee of appellee the City of

Galena Park (the City), serving as a police officer, chief of police, and city

administrator over more than twenty years. Following a tumultuous election and

resulting upheaval in the City’s mayoral office and City Commission, Pruett resigned. He subsequently sought severance pay pursuant to a City ordinance

providing for severance benefits to certain long-term employees and pursuant to a

purported Severance Agreement between him and the City. The City opposed

paying severance benefits. The City filed a petition seeking declaratory judgment

construing the ordinance and Severance Agreement, and Pruett alleged counter-

claims challenging the City’s construction of the ordinance and agreement and

alleging that the City had breached its contract with him. Both parties filed motions

for summary judgment, and, after several interlocutory rulings, the trial court

rendered judgment granting the City’s motion and denying Pruett’s.

On appeal, Pruett contends that the trial court erred (1) in granting the City’s

motion for summary judgment and denying his own motion and (2) in denying his

request for attorney’s fees pursuant to Civil Practice and Remedies Code chapters

37 and 38. Because we conclude that the ordinance in question did not, by itself,

support Pruett’s claim for severance benefits and the purported agreement between

the parties was invalid, we affirm.

Background

Robert C. Pruett served the City of Galena Park as a police officer starting in

1993. He eventually became the Chief of Police in 2000, and he became the City

Administrator in 2012. In 2014, mayoral candidate Esmerelda Moya ran on a

platform that included efforts to eliminate the position of City Administrator.

2 Pruett presented summary judgment evidence that Moya targeted him personally

during this contentious election and, upon her election to office, attempted to have

him removed from office. The governing body of the City—the City

Commission1—voted against removing Pruett.

After this attempt to remove him, the City Commission adopted Ordinance

2015-10, which stated that its purpose was to amend the City’s personnel

ordinance to provide for severance package agreements and benefits for certain

long-term employees. The Ordinance further stated, “It is the intent of this

ordinance to provide severance protection to long term senior Department Heads

and certain Key Employees of the City[.]” The Ordinance defined key terms,

including “Department Head,” which expressly included the City Administrator,

and “Key Employee.” The Ordinance also defined “Severance Agreement” as “the

agreement between the covered employee and the City entered into pursuant to this

ordinance and the terms and conditions of the severance agreement.”

Ordinance 2015-10 then provided for compensation upon termination under

certain circumstances:

If the Department Head or Key Employee’s employment is terminated by the City Commission Without Good Cause or by the Department Head or Key Employee With Good Reason during the employment period, the City Commission shall provide to the Employee the

1 The City is a Texas home rule city operating under a city charter that provides for the business of the City to be conducted by the mayor and four Commissioners. Galena Park charter art. IX, Sec. 1; Galena Park Code § 2-47. 3 accrued obligations, severance compensation and other benefits set forth in this ordinance and in the severance agreement of the parties.

The Ordinance defined “Good Cause” as including “[w]illful or negligent failure to

fulfill and perform the duties required by his job or employment,” and it defined

“Voluntary termination for Good Reason” as including “any willful and deliberate

action by the City Commission that creates a hostile work environment so as to

make continued employment unbearable.” Severance benefits were not available

for terminations by the City with Good Cause or “[i]n the event the Department

Head or Key Employee voluntarily retires, becomes disabled and is unable to

perform his required duties, or dies during his employment.”

The Ordinance set out a method for determining the severance amount,

stating that the amount should be a lump-sum payment consisting of “one month’s

base wages for every year of service” but that “the total severance pay paid to such

employee shall not exceed twenty-four (24) months.” The Ordinance also set out a

procedure to “Contest and Appeal” a termination:

G. Contest and Appeal of termination. (1) The Department Head or Key Employee may contest and appeal the decision of the City Commission to terminate his employment for “Good Cause” by requesting that the decision be submitted to an Arbitration Hearing before an independent hearing examiner or arbitrator within ten (10) days of such employee’s termination. The hearing examiner or arbitrator shall be selected and the hearing shall be held pursuant to the American Arbitration Association Rules and Regulations. (2) The City Commission may also contest and appeal the decision of the Department Head or Key Employee to terminate his employment for “Good Reason” by requesting that the decision be submitted to an

4 Arbitration Hearing before an independent hearing examiner within 10 days of such employee’s delivery of his written notice to terminate his employment for “Good Reason” to the City Secretary of the City of Galena Park. The hearing examiner or arbitrator shall be selected and hearing shall be held pursuant to the American Arbitration Association Rules and Regulations.

The Ordinance also contained a “Severance Agreement” provision:

I. Severance Agreement[.] After the Department Head or Key Employee accumulates twenty (20) years of employment with the City, the City Commission will provide a formal Severance Agreement in such form as it may deem proper and in accordance with the terms and conditions of this ordinance. Such formal agreement must be agreed to and executed by the Department Head or Key Employee in order for such employee to be entitled to the benefits of severance pay provided in this ordinance.

And the Ordinance contained a severability clause, providing that “any section,

paragraph, sentence, clause, or phrase contained in this ordinance” that becomes

illegal, null, or void could be severed and the remaining sections “shall not be

affected thereby.”

Ordinance 2015-10 was adopted by the then-sitting City Commission, but it

was not signed by Mayor Mora. Rather, it was signed by Mayor Pro Tem Maricela

Serna.

On March 15, 2016, Pruett filed suit in federal court regarding Moya’s

unsuccessful attempt to remove Pruett as City Administrator. He sought relief

pursuant to the Age Discrimination in Employment Act and Title VII of the Civil

Rights Act of 1964. These claims were ultimately dismissed.

5 In May 2016, Pruett and the four then-sitting Commissioners—Juan Flores,

Maricela Serna, Cruz Hinojosa, Jr., and Danny Simms—signed a “Severance

Agreement.” The purported Severance Agreement provided for Pruett to receive

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Robert C. Pruett v. City of Galena Park, Counsel Stack Legal Research, https://law.counselstack.com/opinion/robert-c-pruett-v-city-of-galena-park-texapp-2022.