Texas A&M University v. Bryan Glen Hole

CourtCourt of Appeals of Texas
DecidedApril 26, 2006
Docket10-04-00287-CV
StatusPublished

This text of Texas A&M University v. Bryan Glen Hole (Texas A&M University v. Bryan Glen Hole) 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
Texas A&M University v. Bryan Glen Hole, (Tex. Ct. App. 2006).

Opinion

IN THE

TENTH COURT OF APPEALS

 

No. 10-04-00287-CV

Texas A&M University,

                                                                                    Appellant

 v.

Bryan Glen Hole, et al.,

                                                                                    Appellees


From the 272nd District Court

Brazos County, Texas

Trial Court No. 03-000858-CV-272

Opinion

Appellant, Texas A&M University (TAMU), brings this appeal contesting the trial court’s judgment in favor of Appellees.  We will vacate the judgment of the trial court and dismiss the case.

Background

      In October 2002, a student reported hazing in the Parsons Mounted Cavalry (PMC), a unit within the university’s Corps of Cadets.  The university initiated disciplinary action for the misconduct in April 2003.  Before his hearing with TAMU officials, Plaintiff Eric Gonzalez filed a petition seeking a Temporary Restraining Order (TRO) which the trial court granted.  The trial court issued an additional TRO which stopped all PMC-related hearings, all university appellate proceedings, and the enforcement of any sanctions already assessed.  This order was entered before TAMU initiated disciplinary action for some students and before any student exhausted the university’s appellate process.

Additional students filed suit and the actions were consolidated with the Gonzalez suit.  Eventually, twenty-three plaintiffs sought relief from the trial court in the form of a permanent injunction enjoining TAMU from continuing with the student-disciplinary process and a declaration under the Uniform Declaratory Judgments Act as to provisions of the Student Conduct Code, Student Rules, and student-disciplinary process.  The final judgment, among other things, permanently enjoined TAMU from enforcing the sanctions previously assessed against the plaintiffs by the university and pursuing any disciplinary action against the students for conduct that occurred prior to October 2002.  

      TAMU presents five issues for review.  It first challenges the jurisdiction of the trial court.


Ripeness

      Ripeness is a threshold issue that implicates subject-matter jurisdiction and emphasizes the need for a concrete injury.  Patterson v. Planned Parenthood of Houston and Southeast Texas, Inc., 971 S.W.2d 439, 442 (Tex. 1998).  Under the ripeness doctrine, we consider whether, at the time a lawsuit is filed, the facts are sufficiently developed “so that an injury has occurred or is likely to occur, rather than being contingent or remote.”  Waco Indep. Sch. Dist. v. Gibson, 22 S.W.3d 849, 851-52 (Tex. 2000) (citing Patterson, 971 S.W.2d at 442).  By focusing on the concrete injury, the ripeness doctrine allows courts to avoid premature adjudication, and serves the constitutional interests in prohibiting advisory opinions.  Id.  Because the plaintiffs had not yet completed the university’s disciplinary process, they did not have a concrete injury and the case was not ripe for adjudication. 

      Seeking a declaration of rights under the Uniform Declaratory Judgments Act is not sufficient to avoid the ripeness doctrine.  This act is merely a procedural device for deciding cases already within a court’s jurisdiction rather than a legislative enlargement of a court’s power, permitting the rendition of advisory opinions.  Texas Ass’n of Bus. v. Texas Air Control Bd., 852 S.W.2d 440, 444 (Tex. 1993).

      Because plaintiffs’ claims were not ripe, the trial court lacked subject-matter jurisdiction.[1]  Patterson, 971 S.W.2d at 442. 

      Having determined that the trial court lacked jurisdiction, we need not decide the remaining issues.

Conclusion

      For the reasons stated, we vacate the trial court’s judgment and dismiss the caseTex. R. App. P. 43.2(e).

BILL VANCE

Justice

Before Chief Justice Gray,

Justice Vance, and

Justice Reyna

            (Chief Justice Gray dissenting)

Judgment vacated; Case dismissed

Opinion delivered and filed April 26, 2006

[CV06]



    [1]   Courts should tread lightly in fashioning remedies for due process violations that affect the academic decisions of state-supported universities.  Univ. of Texas Med. Sch. at Houston v. Than, 901 S.W.2d 926, 934 (Tex. 1995).

nn. § 31.03(b)(1) (Vernon Pamph. 2010).  Consent is not effective if it is induced by deception.  Tex. Penal Code Ann. § 31.01(3)(A) (Vernon Pamph. 2010).  Deception means:

(A) creating or confirming by words or conduct a false impression of law or fact that is likely to affect the judgment of another in the transaction, and that the actor does not believe to be true;

(B) failing to correct a false impression of law or fact that is likely to affect the judgment of another in the transaction, that the actor previously created or confirmed by words or conduct, and that the actor does not now believe to be true;

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Texas A&M University v. Bryan Glen Hole, Counsel Stack Legal Research, https://law.counselstack.com/opinion/texas-am-university-v-bryan-glen-hole-texapp-2006.