San Antonio Independent School District v. McKinney

936 S.W.2d 279, 1996 WL 714817
CourtTexas Supreme Court
DecidedJanuary 31, 1997
Docket95-0522
StatusPublished
Cited by114 cases

This text of 936 S.W.2d 279 (San Antonio Independent School District v. McKinney) is published on Counsel Stack Legal Research, covering Texas Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
San Antonio Independent School District v. McKinney, 936 S.W.2d 279, 1996 WL 714817 (Tex. 1997).

Opinions

ENOCH, Justice.

The issue in this case is whether a prior federal court judgment precludes a subsequent action in state court asserting state law claims omitted in the federal action. In particular, we must decide whether an independent school district is entitled to Eleventh Amendment immunity from suit in federal court such that the federal court would have lacked jurisdiction of the omitted state law claims. The court of appeals concluded that a school district is an arm of the state entitled to Eleventh Amendment immunity. 897 S.W.2d 879. Because we conclude that an independent school district is more like a county or city than it is like an arm of the state, and is amenable to suit in federal court, we hold that res judicata precludes litigation of the omitted state law claims in state court. We reverse the judgment of the court of appeals and render judgment for the independent school district and its board of trustees.

Charles McKinney was fired from his job as a band teacher with the San Antonio Independent School District (SAISD). McKinney, an African-American, contends that the termination was race-related. Consequently, he filed a race discrimination lawsuit in federal district court. While his federal lawsuit was pending, McKinney administratively appealed his termination to the Commissioner of Education of the Texas Education Agency, arguing that SAISD did not follow proper procedures in firing him. The Commissioner ruled in his favor, but the school district refused to reinstate McKinney.

While his administrative appeal was pending, McKinney told the federal court that he intended to amend his federal complaint “to present all his claims arising from the same facts and transactions ... once a final Agency ruling is obtained.” However, he never did so. The federal court eventually rendered a summary judgment against McKinney on his race discrimination claim.

McKinney then filed this suit against SAISD and its board of trustees in state court for breach of contract and to enforce the Commissioner’s reinstatement order. SAISD moved for summary judgment, pri[281]*281marily asserting that McKinney’s suit was barred by res judicata because of the prior judgment in the federal race discrimination lawsuit. The trial court granted SAISD’s motion. The court of appeals held that because an independent school district is an arm of the state, the Eleventh Amendment prevented McKinney from bringing his state claims against SAISD in federal court and thus, res judicata did not bar his current state suit. 897 S.W.2d at 884. We disagree.

I

Because the first lawsuit at issue in this case was decided in federal court, federal law controls the determination of whether res judicata bars the present state court proceeding. Eagle Properties, Ltd. v. Scharbauer, 807 S.W.2d 714, 718 (Tex.1990); Jeanes v. Henderson, 688 S.W.2d 100, 103 (Tex.1985). Under federal law, the doctrine of res judicata will apply if (1) the parties in both suits are identical; (2) the prior judgment was rendered by a court of competent jurisdiction; (3) there is a final judgment on the merits; and (4) the same cause of action is involved in both cases. Eagle Properties, 807 S.W.2d at 718. Additionally, even if the above four requirements are established, res judicata will not apply if the federal court (1) lacked jurisdiction over the omitted state law claims, or (2) possessed jurisdiction over the omitted state law claims but would clearly have declined to exercise that jurisdiction as a matter of discretion. Id. at 718; Jeanes, 688 S.W.2d at 104.

As framed by the parties, the dispositive question is whether the federal court lacked jurisdiction because of the Eleventh Amendment. There is no question that the federal court had supplemental jurisdiction under 28 U.S.C. § 1367.1 And McKinney has not argued that had the federal court possessed jurisdiction it would clearly have declined to exercise supplemental jurisdiction over his omitted state law claims as a matter of discretion. Moreover, at oral argument, McKinney confirmed that his only argument against res judicata is that the Eleventh Amendment prevented the federal court from hearing his state law claims. Accordingly, we do not have before us the question of whether the federal district court “would clearly have declined” to exercise its supplemental jurisdiction over McKinney’s state law claims as a matter of discretion. 28 U.S.C. § 1367(c); see also Eagle Properties, 807 S.W.2d at 718; Jeanes, 688 S.W.2d at 104. Instead, we must decide whether the San Antonio Independent School District is in effect the “State” so that the federal court would have lacked jurisdiction to consider McKinney’s state law claims.

II

The Eleventh Amendment limits the federal courts’ judicial power specified in Article III, Section 2 of the United States Constitution. It provides:

The Judicial power of the United States shall not be construed to extend to any suit in law or equity, commenced or prosecuted against one of the United States by Citizens of another State, or by Citizens or Subjects of any Foreign State.

U.S. CONST, amend. XI. The Amendment by its terms does not bar suits against a state by its own citizens. However, the United States Supreme Court has consistently held that an unconsenting state is immune from suits brought in federal courts by her own citizens as well as by citizens of another state. Edelman v. Jordan, 415 U.S. 651, 662-63, 94 S.Ct. 1347, 1355-56, 39 L.Ed.2d 662 (1974) (citations omitted). Accordingly, if against the State of Texas or an arm of the state, McKinney’s claims are within the scope of the Eleventh Amendment.

By its terms, the protection afforded by the Eleventh Amendment is only available to “one of the United States.” Lake Country Estates, Inc. v. Tahoe Regional Planning Agency, 440 U.S. 391, 400, 99 S.Ct. 1171, 1177, 59 L.Ed.2d 401 (1979). As such, whether a particular governmental entity enjoys the federal constitutional protection af[282]*282forded to the states under the Eleventh Amendment is a question of federal law. See Cowles v. Mercer, 7 Wall. 118, 19 L.Ed. 86 (1868) (state law cannot defeat jurisdiction given by the Constitution). Under federal law, some state agencies exercising state power are permitted to invoke the Amendment to protect the state treasury from liability that would have had essentially the same practical consequences as a judgment against the state itself. Lake Country, 440 U.S. at 400-01, 99 S.Ct. at 1176-77. But the United States Supreme Court has “consistently refused to construe the Amendment to afford protection to political subdivisions such as counties and municipalities, even though such entities exercise a ‘slice of state power.’ ” Id. at 401, 99 S.Ct. at 1177.

Although the ultimate question of federal jurisdiction under the Eleventh Amendment is a federal constitutional question, state law informs the determination. Mt.

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Bluebook (online)
936 S.W.2d 279, 1996 WL 714817, Counsel Stack Legal Research, https://law.counselstack.com/opinion/san-antonio-independent-school-district-v-mckinney-tex-1997.