Stephen F. Austin State University v. Diane Flynn

CourtCourt of Appeals of Texas
DecidedJanuary 21, 2004
Docket12-03-00240-CV
StatusPublished

This text of Stephen F. Austin State University v. Diane Flynn (Stephen F. Austin State University v. Diane Flynn) 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
Stephen F. Austin State University v. Diane Flynn, (Tex. Ct. App. 2004).

Opinion

NO. 12-03-00240-CV



IN THE COURT OF APPEALS



TWELFTH COURT OF APPEALS DISTRICT



TYLER, TEXAS

STEPHEN F. AUSTIN STATE

§
APPEAL FROM THE 145TH

UNIVERSITY,

APPELLANT



V.

§
JUDICIAL DISTRICT COURT OF



DIANE FLYNN,

APPELLEE

§
NACOGDOCHES COUNTY, TEXAS

MEMORANDUM OPINION

Stephen F. Austin State University ("SFA") appeals from the trial court's denial of its plea to the jurisdiction and motion to dismiss. Appellee, Diane Flynn, sued SFA pursuant to the Texas Tort Claims Act for personal injuries. In two issues, SFA asserts the trial court erred in determining it had waived sovereign immunity. We affirm.



Background

On August 7, 2000, Flynn and her husband were riding their bikes along the Lanana Creek Trail in Nacogdoches. As she rode on the trail adjacent to a shot put field on SFA's campus, she was hit by a stream of water from an oscillating sprinkler located by the shot put field. The sprinkler head was about four feet from the path she rode on. The water hit her on the right side of her head and the force threw her off her bike.

Flynn sued SFA for personal injuries she incurred from the accident. Flynn alleged in her petition that the portion of the trail running through SFA property was located on an easement owned by the city of Nacogdoches. She alleged that SFA's negligent use of personal property, the sprinkler, caused her injuries. Specifically, she contends SFA negligently caused the water's path to cross the trail where people commonly walk and bicycle and SFA activated the sprinkler at a time of day when people were likely to use the trail.

Alternatively, she alleged that if SFA did occupy that portion of the trail where she was injured, SFA was engaged in a negligent activity on its premises which caused her injuries. She also alleged alternatively that if SFA occupied the trail on which she was injured, and the use of the water sprinkler did not constitute an activity, the premises on which she was injured was not reasonably safe in that the sprinkler came on at unknown times where people were expected to walk, bicycle, and travel, creating an extreme and unjustifiable risk of injury to those people. She further alleged that SFA failed to warn of the dangerous condition, failed to repair or remove the dangerous condition, created the unsafe condition by allowing the water sprinkler to be installed such that a forceful stream of water came on at unknown times, and reasonably should have known of the danger the sprinkler posed.

Finally, she alleged that all of the actions and omissions of SFA were of such a character to make SFA guilty of gross negligence and/or malice. She asserted that SFA's conduct involved an extreme degree of risk, considering the probability and the magnitude of potential harm to others. Further, she alleged that SFA engaged in conduct with conscious indifference to the rights, safety, or welfare of others.

SFA filed a plea to the jurisdiction contending it enjoys sovereign immunity. Specifically, it asserted Flynn did not claim any injury resulting from any alleged negligent act involving the operation or use of motor-driven vehicles or equipment, failed to state any cognizable claim based on an alleged use of personal property, and her allegations amount to claims involving a premise defect. SFA argued that Flynn's allegations are governed by the recreational use statute which bars claims of ordinary negligence. Further, it argued that Flynn's allegations of gross negligence fail to state a cognizable claim and were pleaded as a sham in an attempt to wrongfully obtain jurisdiction. In response to Flynn's argument that she was injured on an easement granted to the city of Nacogdoches, SFA asserted in its supplemental plea that, if the easement exists, it owed no duty to Flynn whatsoever. Finally, SFA contended that the acts about which Flynn complains are discretionary acts for which SFA retains immunity from suit.

The trial court found that SFA's watering of the grounds is a discretionary function while the placement and operation of the sprinkler system constitute policy implementation. The court denied SFA's plea to the jurisdiction and motion to dismiss.



Applicable Law

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). A party suing a governmental entity must establish the State's consent, which may be alleged either by reference to a statute or to express legislative permission. Id. Where the governmental entity denies it consented to suit, and maintains instead that it retains sovereign immunity, it must plead and prove that affirmative defense. Davis v. City of San Antonio, 752 S.W.2d 518, 520 (Tex. 1988). 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. Jones, 8 S.W.3d at 638. 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).

A plea to the jurisdiction is a dilatory plea, the purpose of which is to defeat a cause of action without regard to whether the claims asserted have merit. Id. A plea to the jurisdiction contests the trial court's authority to determine the subject matter of the cause of action. Cornyn v. County of Hill, 10 S.W.3d 424, 427 (Tex. App.-Waco 2000, no pet.). Subject matter jurisdiction is a legal question, and the plea to the jurisdiction is reviewed under a de novo standard of review. Mayhew v. Town of Sunnyvale, 964 S.W.2d 922, 928 (Tex. 1998). Dismissing a cause of action for lack of subject matter jurisdiction is only proper when it is impossible for the plaintiff's petition to confer jurisdiction on the trial court. Harris County v. Cypress Forest Pub. Util. Dist., 50 S.W.3d 551

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Stephen F. Austin State University v. Diane Flynn, Counsel Stack Legal Research, https://law.counselstack.com/opinion/stephen-f-austin-state-university-v-diane-flynn-texapp-2004.