State v. Elkanah Henry King and Mary King, Individually & as Representatives of the Estate of Alfred K. King

CourtCourt of Appeals of Texas
DecidedNovember 26, 2003
Docket12-03-00179-CV
StatusPublished

This text of State v. Elkanah Henry King and Mary King, Individually & as Representatives of the Estate of Alfred K. King (State v. Elkanah Henry King and Mary King, Individually & as Representatives of the Estate of Alfred K. King) 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
State v. Elkanah Henry King and Mary King, Individually & as Representatives of the Estate of Alfred K. King, (Tex. Ct. App. 2003).

Opinion

NO. 12-03-00179-CV



IN THE COURT OF APPEALS



TWELFTH COURT OF APPEALS DISTRICT



TYLER, TEXAS



THE STATE OF TEXAS, RUSK STATE § APPEAL FROM THE 2ND

HOSPITAL, AND TEXAS DEPARTMENT

OF MENTAL HEALTH AND MENTAL

RETARDATION, APPELLANTS



V.
§ JUDICIAL DISTRICT COURT OF



ELKANAH HENRY KING AND MARY

KING, INDIVIDUALLY, AND AS

REPRESENTATIVES OF THE

ESTATE OF ALFRED K. KING,

APPELLEES

§ CHEROKEE COUNTY, TEXAS





MEMORANDUM OPINION

Elkanah Henry King and Mary King, individually, and as representatives of the estate of Alfred K. King (King), sued the State of Texas, Rusk State Hospital, and the Texas Department of Mental Health and Mental Retardation (collectively, the State) pursuant to the Texas Tort Claims Act. Both sides appeal from the trial court's order granting in part and denying in part the State's plea to the jurisdiction. The State asserts that it did not waive sovereign immunity under any theory and that Elkanah King does not have standing to bring suit. King contends that under the facts of this case, the State waived sovereign immunity. We affirm in part, reverse in part, and render judgment that the State's plea to the jurisdiction is granted.



Background

Alfred K. King suffered from a mental illness and was known to be suicidal. He was committed to Rusk State Hospital for treatment on January 23, 1996. On January 28, he was placed on "close observation" for his suicidal ideations. An attendant was assigned to watch Alfred at all times. However, the attendant on duty during the night of January 29 and into the morning of January 30 was confused as to which bed Alfred was in. Early on the morning of January 30, Alfred was found dead in a shower stall, hanging from his own shoelaces that were tied to the shower head. Alfred's parents, King, sued the State and two individuals not parties to this appeal. They filed a motion for partial summary judgment arguing entitlement to judgment as a matter of law against the State on the issues of immunity, under both the Tort Claims Act and Section 321.003 of the Texas Health and Safety Code, (1) and negligence. King alleged that the State used or misused the shoelaces by allowing Alfred to keep them in his possession and used or misused the beds by failing to properly identify Alfred's bed, which led to the assigned attendant's confusion in watching the wrong patient. The State filed a plea to the jurisdiction claiming King lacks standing and that the State is entitled to sovereign immunity. The trial court denied King's motion for partial summary judgment. It denied the State's plea to the jurisdiction as to standing and immunity relating to the use or misuse of the beds. It granted the State's plea as to immunity relating to the use or misuse of the shoelaces and Section 321.003 of the Health and Safety Code. Each side appeals the portions of the rulings that are adverse to it. (2)



Sovereign Immunity

Applicable Law

Sovereign immunity is an affirmative defense that must be pleaded and proved. Davis v. City of San Antonio, 752 S.W.2d 518, 520 (Tex. 1988). 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) (per curiam). 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).

The Texas Tort Claims Act (the "Act") provides a limited waiver of sovereign immunity in certain circumstances:



A governmental unit is liable for:



(1) property damage, personal injury, and death proximately caused by the wrongful act or omission or the negligence of an employee acting within his scope of employment if:



(A) the property damage, personal injury, or death arises from the operation or use of a motor-driven vehicle or motor driven equipment; and



(B) the employee would be personally liable to the claimant according to Texas law; and



(2) personal injury and death so caused by a condition or use of tangible personal or real property if the governmental unit would, were it a private person, be liable to the claimant according to Texas law.



Tex. Civ. Prac. & Rem. Code Ann. § 101.021 (Vernon 1997). To sue the State for a tort, the pleadings must state a claim under the Act. Jones

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Related

Bland Independent School District v. Blue
34 S.W.3d 547 (Texas Supreme Court, 2000)
Baston v. City of Port Isabel
49 S.W.3d 425 (Court of Appeals of Texas, 2001)
University of Texas Medical Branch v. York
871 S.W.2d 175 (Texas Supreme Court, 1994)
Texas Ass'n of Business v. Texas Air Control Board
852 S.W.2d 440 (Texas Supreme Court, 1993)
Texas Department of Criminal Justice v. Miller
51 S.W.3d 583 (Texas Supreme Court, 2001)
Wichita Falls State Hospital v. Taylor
106 S.W.3d 692 (Texas Supreme Court, 2003)
Kerrville State Hospital v. Clark
923 S.W.2d 582 (Texas Supreme Court, 1996)
Texas Department of Criminal Justice v. Diller
127 S.W.3d 7 (Court of Appeals of Texas, 2002)
Dallas Cty. Mental Health and Mental Retardation v. Bossley
968 S.W.2d 339 (Texas Supreme Court, 1998)
Salcedo v. El Paso Hospital District
659 S.W.2d 30 (Texas Supreme Court, 1983)
Lacy v. Rusk State Hospital
31 S.W.3d 625 (Court of Appeals of Texas, 2000)
Texas Department of Transportation v. Jones
8 S.W.3d 636 (Texas Supreme Court, 1999)
Mayhew v. Town of Sunnyvale
964 S.W.2d 922 (Texas Supreme Court, 1998)
Robinson v. Central Texas MHMR Center
780 S.W.2d 169 (Texas Supreme Court, 1989)
Davis v. City of San Antonio
752 S.W.2d 518 (Texas Supreme Court, 1988)
Lowe v. Texas Tech University
540 S.W.2d 297 (Texas Supreme Court, 1976)

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State v. Elkanah Henry King and Mary King, Individually & as Representatives of the Estate of Alfred K. King, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-elkanah-henry-king-and-mary-king-individua-texapp-2003.