Texas Department of Transportation v. Jimmie Lee Lofton

CourtCourt of Appeals of Texas
DecidedOctober 19, 2023
Docket09-22-00256-CV
StatusPublished

This text of Texas Department of Transportation v. Jimmie Lee Lofton (Texas Department of Transportation v. Jimmie Lee Lofton) 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 Department of Transportation v. Jimmie Lee Lofton, (Tex. Ct. App. 2023).

Opinion

In The

Court of Appeals

Ninth District of Texas at Beaumont

__________________

NO. 09-22-00256-CV __________________

TEXAS DEPARTMENT OF TRANSPORTATION, Appellant

V.

JIMMIE LEE LOFTON, Appellee

__________________________________________________________________

On Appeal from the 136th District Court Jefferson County, Texas Trial Cause No. D-204,737 __________________________________________________________________

MEMORANDUM OPINION

In this accelerated interlocutory appeal, the Texas Department of

Transportation (TxDOT) challenges the denial of its “Motion for Traditional and No

Evidence Summary Judgment and to Dismiss for Want of Jurisdiction” in which it

asserted sovereign immunity and requested dismissal of Jimmie Lee Lofton’s

personal injury lawsuit. See Tex. Civ. Prac. & Rem. Code Ann. § 51.014(a)(8).1 In

1We note that Jimmie Lee Lofton’s name is misspelled throughout the clerk’s

record and in the final judgment as Jimmy Lee Lofton. 1 two issues, TxDOT contends the trial court erred by denying its Motion for

Traditional and No Evidence Motion for Summary Judgment and To Dismiss for

Want of Jurisdiction because (1) the pothole is not a special defect and there is no

evidence that TxDOT had actual knowledge of the danger of the pothole when the

accident occurred or (2) that the pothole posed an unreasonable risk of harm. TxDOT

argues that without such evidence, there is no waiver of sovereign immunity under

the Texas Tort Claims Act (“TTCA”), and the trial court is deprived of subject matter

jurisdiction. As discussed below, we reverse the trial court’s Order and dismiss

Lofton’s suit for lack of jurisdiction.

BACKGROUND

In his petition, Lofton alleged that on the night of September 24, 2018, Lofton

was riding his motorcycle eastbound in the far right outside lane of Interstate 10 in

Jefferson County when he hit an alleged “special defect” in the roadway, which he

described as “a previously improperly repaired” pothole and crack in the roadway.

As a result of hitting the pothole, he lost control of his motorcycle and suffered

multiple injuries. Lofton claimed that he was an “invitee” on property possessed,

controlled and maintained by TxDOT. Lofton claimed that TxDOT knew or should

have known of the dangerous premises condition, which posed an unreasonable risk

of harm. Asserting causes of action for special defect and in the alternative a claim

for a premises defect, Lofton alleged that he suffered personal injuries caused by a

2 condition or use of the property and that TxDOT’s immunity is waived, making it

liable for his injuries and damages.

In its answer, TxDOT raised the affirmative defense of sovereign immunity.

The case went to trial, but the jurors were unable to reach a verdict and a mistrial

was declared. TxDOT then filed its combined “Motion for Traditional and No

Evidence Summary Judgment and to Dismiss for Want of Jurisdiction.” In its

Motion, TxDOT asserted sovereign immunity against suit and liability, and it

requested dismissal of the suit. TxDOT asserted that the condition complained of

was not a special defect. It further argued that no evidence exists to show that

TxDOT had actual knowledge of the condition, as required to find liability for

injuries caused by an ordinary premises defect. TxDOT supported its motion with

trial testimony from several witnesses, including: Tiffany Lofton, Lofton’s wife;

Trooper Kasey Carrier, who investigated the accident; Noel Salac, a TxDOT area

engineer; and Todd Dinger, a TxDOT maintenance supervisor. TxDOT also attached

photographs Tiffany took the day after the accident and photographs Trooper Carrier

took the night of the accident.

In his “Response to Defendant’s Motion for Traditional and No Evidence

Motion for Summary Judgment and to Dismiss for Want of Jurisdiction,” Lofton

asserted that evidence at trial showed the condition of the roadway was a special

defect or, in the alternative, a premise defect, and that fact issues exist on the issue

3 of “actual knowledge” of a dangerous condition and whether there was an

“unreasonable risk of harm.” In addition to the trial testimony of the four witnesses,

Lofton’s supporting evidence included a photograph of the pothole taken by Trooper

Carrier, a TxDOT daily activity report for the day after the accident occurred, and

the crash report. The trial court denied TxDOT’s Motion for Traditional and No

Evidence Motion for Summary Judgment and to Dismiss for Want of Jurisdiction.

STANDARD OF REVIEW

We have jurisdiction to review an interlocutory order in which the trial court

“grants or denies a plea to the jurisdiction by a governmental unit[.]” Tex. Civ. Prac.

& Rem. Code Ann. §§ 51.014(a)(8); see Tex. Civ. Prac. & Rem. Code Ann. §

101.001(3)(A) (defining governmental unit to include the state and all agencies of

the government that constitute the state, including departments). Both a plea to the

jurisdiction and a motion for summary judgment are appropriate vehicles to

challenge a trial court’s subject-matter jurisdiction. Bland Indep. Sch. Dist. v. Blue,

34 S.W.3d 547, 554 (Tex. 2000). Sovereign immunity deprives a trial court of

subject-matter jurisdiction over suits against the State or certain governmental units

unless the State has consented to suit. Tex. Dep’t of Parks & Wildlife v. Miranda,

133 S.W.3d 217, 224 (Tex. 2004) (citations omitted). The issue in this case is

whether the State waived immunity through the limited waiver provided for in the

TTCA. See Tex. Civ. Prac. & Rem. Code Ann. §§ 101.001–.109.

4 Whether a trial court has subject-matter jurisdiction is a question of law

reviewed de novo. See Miranda, 133 S.W.3d at 226. To invoke the trial court’s

subject-matter jurisdiction, the plaintiff must allege facts that affirmatively

demonstrate that the trial court has jurisdiction to hear the case. Id. “If the evidence

creates a fact question regarding the jurisdictional issue, then the trial court cannot

grant the plea to the jurisdiction, and the fact issue will be resolved by the fact

finder.” Id. at 227–28. However, if the relevant evidence is undisputed or fails to

raise a fact question on the jurisdictional issue, a district court rules on the plea to

the jurisdiction as a matter of law. Id. at 228. If a party challenges the existence of

jurisdictional facts, we consider the evidence submitted by the parties to resolve the

jurisdictional issue raised. Id. at 227 (citation omitted).

A party who seeks a no-evidence summary judgment contends that there is no

evidence of one or more elements of a claim on which the other party has the burden

of proof at trial. Tex. R. Civ. P. 166a(i). If the nonmovant produces more than a

scintilla of evidence that raises a genuine issue of material fact as to the challenged

element, summary judgment is improper. See id.; King Ranch, Inc. v. Chapman, 118

S.W.3d 742, 751 (Tex. 2003). If reasonable, fair-minded people could differ in their

conclusions, there is more than a scintilla of probative evidence. Chapman, 118

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