Texas Department of Public Safety v. Rocio Elizabeth Reyes, Individually and as Next Friend of Sebastian Villa Reyes

Court of Appeals of Texas·Decided September 16, 2025·No. 08-25-00048-CV·Published

Opinion

COURT OF APPEALS

EIGHTH DISTRICT OF TEXAS

EL PASO, TEXAS

Appellees Rocio Elizabeth Reyes and her minor son, S.V.R. 2 On behalf of herself and her son, Reyes filed suit against the law enforcement agencies involved in the pursuit, including Appellant Texas Department of Public Safety. 3 DPS filed a plea to the jurisdiction claiming sovereign immunity from suit and now appeals the trial court’s order denying its plea. We reverse and render judgment dismissing the claims against DPS.

I. FACTS

On an afternoon in September 2021, the United States Border Patrol requested assistance in apprehending Chaparro who was suspected of human trafficking. DPS troopers Joshua Patlan, Sarah Booth-Hernandez, Brian Coleman, and Micah Rucker were in the area and responded to the request.

As Patlan approached the Border Patrol checkpoint, he saw Chaparro make an illegal U-

turn to evade a Border Patrol officer. He began to pursue Chaparro at speeds of over 120 miles per hour and officers from other law enforcement agencies joined the pursuit. Meanwhile, Booth- Hernandez, Coleman, and Rucker were all located in the direction towards which Chaparro was headed. They each attempted to stop Chaparro with “stop sticks” or “spike strips” (used to puncture and deflate a suspect’s tires), but only Rucker was able to successfully deploy them before Chaparro reached his location. Chaparro drove over the spike strip with one tire but did not lose control of his vehicle and continued driving. Rucker did not participate further but Booth- Hernandez and Coleman joined the pursuit.

The pursuit continued for 28 miles, approximately eight of which were after Chaparro lost his tire. At times, Chaparro passed in no-passing zones or veered off the road to pass drivers on

2 We refer to the minor by his initials to protect his privacy. Tex. R. App. P. 9.9(a)(3) (sensitive data includes the name of a person who was a minor when the suit was filed). 3 Reyes also included as defendants Chaparro and companies related to Avis Budget Car Rental from which Chaparro rented his vehicle. Those defendants are not parties to this appeal.

the right. Although the three DPS troopers continued the chase, none were close enough behind Chaparro to witness the accident.

DPS Sergeant Christopher Tamez conducted a review of DPS actions after the accident.

He stated that he “believe[ed] that a reasonable and prudent officer, under the same or similar circumstances as Trooper Patlan, could have believed that his conduct was justified based on the information he possessed when the conduct occurred[.]” Also submitted with the plea to the jurisdiction were videos from the dashboard and body cameras of the troopers and the incident and crash reports.

Reyes filed an unverified response to the plea to the jurisdiction. She asked that the trial court defer its ruling to allow her to conduct discovery on the jurisdictional issues. She also argued that the plea to the jurisdiction should be denied because there were fact issues about whether DPS’s sovereign immunity was waived and, if so, whether an exception to the waiver applied. She did not attach any evidence to her response.

After a non-evidentiary hearing, the trial court took the case under advisement and, a week later, denied the plea to the jurisdiction. The trial court did not state the basis for its ruling.

DPS filed this interlocutory appeal. Tex. Civ. Prac. & Rem. Code Ann. § 51.014(a)(8)

(allowing for an interlocutory appeal of a ruling on a plea to the jurisdiction by a governmental unit). DPS claims that it was immune from suit and entitled to a dismissal on its plea to the jurisdiction for four reasons. First, DPS argues that its sovereign immunity was not waived because Reyes failed to show that the accident was caused by DPS’s negligent use of a motor vehicle (issue three) or tangible personal property (issue four). Further, it argues that immunity was not waived because the troopers had official immunity and could not be held personally liable (issue two). Even if immunity was waived, DPS contends, the troopers’ conduct brought them within the emergency exception to the waiver of immunity (issue one). Finally, DPS argues that even if we agree with the trial court that immunity from suit was waived, DPS urges that the trial court erred

in failing to dismiss Reyes’s claims for exemplary damages, for which there is no waiver (issue five).

II. ANALYSIS

A. Sovereign immunity and standard of review Texas and its governmental units are immune from liability and suit unless the Legislature has expressly waived immunity. Rusk State Hosp. v. Black, 392 S.W.3d 88, 93–94 (Tex. 2012). DPS, as a state agency, is a governmental unit protected by immunity. Tex. Gov’t Code Ann. § 411.002(a); Tex. Civ. Prac. & Rem. Code Ann. § 101.001(3)(a). Plaintiffs suing a governmental unit have the burden of pleading and establishing a waiver of immunity. City of Austin v. Powell, 704 S.W.3d 437, 447 (Tex. 2024). A governmental unit asserting its immunity can challenge the sufficiency of the pleadings, i.e., that they do not allege facts that would result in a waiver of immunity, or it can challenge the accuracy or existence of the facts alleged. Alamo Heights Indep. Sch. Dist. v. Clark, 544 S.W.3d 755, 770 (Tex. 2018). The burden of proof and standard of review is like that for summary judgments. When the challenge is to the facts and the government defendant submits evidence in support of its plea to the jurisdiction, the burden shifts to the plaintiff to submit evidence that raises a genuine issue of material fact. Id.at 770–71 “[W]e must take as true all evidence favorable to the plaintiff, indulging every reasonable inference and resolving any doubts in the plaintiff’s favor” but at the same time, “we cannot disregard evidence necessary to show context, and we cannot disregard evidence and inferences unfavorable to the plaintiff if reasonable jurors could not.” Id.at 771; City of San Antonio v. Maspero, 640 S.W.3d 523, 528–29 (Tex. 2022). A plea to the jurisdiction must be denied if there remains a question of fact on which jurisdiction depends. Id. We review a trial court’s jurisdictional ruling de novo. Tex. Dep’t of Parks & Wildlife v. Miranda, 133 S.W.3d 217, 26 (Tex. 2004).

B. Waiver of immunity Relevant to this case, the Texas Tort Claims Act waives immunity for the following:

(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 (emphasis added).

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Texas Department of Public Safety v. Rocio Elizabeth Reyes, Individually and as Next Friend of Sebastian Villa Reyes, (Tex. Ct. App. 2025).

Texas Department of Public Safety v. Rocio Elizabeth Reyes, Individually and as Next Friend of Sebastian Villa Reyes (Texas Department of Public Safety v. Rocio Elizabeth Reyes, Individually and as Next Friend of Sebastian Villa Reyes) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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