Texas Education Agency Edward O'Neil, Director of Texas Education Agency And Mike Morath, Commissioner of Education v. Devereux Texas League City

CourtCourt of Appeals of Texas
DecidedMay 10, 2023
Docket03-22-00172-CV
StatusPublished

This text of Texas Education Agency Edward O'Neil, Director of Texas Education Agency And Mike Morath, Commissioner of Education v. Devereux Texas League City (Texas Education Agency Edward O'Neil, Director of Texas Education Agency And Mike Morath, Commissioner of Education v. Devereux Texas League City) 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.

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Texas Education Agency Edward O'Neil, Director of Texas Education Agency And Mike Morath, Commissioner of Education v. Devereux Texas League City, (Tex. Ct. App. 2023).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN

NO. 03-22-00172-CV

Texas Education Agency; Edward O’Neil, Director of Texas Education Agency; and Mike Morath, Commissioner of Education, Appellants

v.

Devereux Texas League City, Appellee

FROM THE 459TH DISTRICT COURT OF TRAVIS COUNTY NO. D-1-GN-21-007028, THE HONORABLE AMY CLARK MEACHUM, JUDGE PRESIDING

MEMORANDUM OPINION

Devereux Texas League City sued the Texas Education Agency (TEA), as well as

TEA Commissioner Mike Morath and TEA Director Edward O’Neil (the Officials), seeking

declaratory and injunctive relief after the Officials revoked Devereux’s eligibility to receive

government funds for certain services it offered. The TEA and the Officials filed a plea to the

jurisdiction, which the trial court denied. The TEA and the Officials perfected this interlocutory

appeal from the trial court’s order. We will reverse the trial court’s order and render judgment

dismissing Devereux’s case.

FACTUAL AND PROCEDURAL BACKGROUND

Federal law provides mandates to “ensure that all children with disabilities have

available to them a free appropriate public education [(FAPE)] that emphasizes special education

and related services designed to meet their unique needs and prepare them for further education, employment, and independent living.” 20 U.S.C. § 1400(d)(1)(A); accord 34 C.F.R. §§ 300.17,

.101(a) (2023). For a state to receive assistance under the Individuals with Disabilities Education

Act, see 20 U.S.C. §§ 1400–1450, the state must submit a plan of policies and procedures that

meets—to the satisfaction of the Secretary of Education—conditions set forth in relevant

Department of Education regulations, see 34 C.F.R. § 300.100 (2023) (citing 34 C.F.R.

§§ 300.101–.176 (2023)).

Special-needs and disabled children sometimes receive their FAPEs through

placements in private facilities where the students can both receive their education and live

full-time. These are known as “nonpublic residential placements.” In Texas, the TEA has

promulgated rules governing contracts for nonpublic residential placements among its broader set

of rules intended to set forth Texas’s plan for implementing federal policies for disabled students.

See 19 Tex. Admin. Code § 89.1092 (2020) (Texas Education Agency, Contracting for Residential

Educational Placements for Students with Disabilities). A Texas local education agency (LEA),

see 34 C.F.R. § 300.28(a) (2023), with responsibility for a disabled student “may contract with

a . . . private facility, institution, or agency inside or outside of this state for the provision

of services to students with disabilities.” Tex. Educ. Code § 29.008(a). The LEA may also

“contract for residential placement of a student when the student’s admission, review, and

dismissal . . . committee determines that a residential placement is necessary in order for the

student to receive a” FAPE. 19 Tex. Admin. Code § 89.1092(a). In the context of the contracting

process between the LEA and the private facility, the “contract for residential placement,” see

Tex. Educ. Code § 29.008(a), and “the facility’s education program,” see 19 Tex. Admin. Code

§ 89.1092(a)(2), “must be approved by” the TEA Commissioner to receive government funds. The

2 Commissioner is to keep a list of the facilities he has approved for contracting. See id.

§ 89.1092(b)(1)–(3).

Devereux’s petition alleges that it runs a campus of facilities in southeast Texas at

which it offers nonpublic residential placements to Texas and non-Texas disabled students. In

2021, following an investigation of Devereux’s facilities, the TEA and the Officials revoked

Devereux’s approval for contracting with Texas LEAs. The TEA sent Devereux a Notification

of Approval Status Change to notify it that it was no longer approved for contracting. The

Notification stated that Devereux’s approval status was changed because of “Specific Areas of

Noncompliance” explained in an enclosure sent with the letter. The enclosure included allegations

that children at Devereux’s facilities had been unlawfully restrained or secluded and cited statutes

and regulations that TEA personnel believed Devereux had violated. Devereux disputed the

allegations and asserted that any violations occurred outside the educational realm of its program,

but the TEA refused to reconsider its position and notified Devereux that its “facility is no longer

approved to offer nonpublic residential placements, to include any placements made by LEAs.”

Devereux sued the TEA and the Officials, seeking declaratory and injunctive relief.

In its claim against the TEA, Devereux alleged that “[t]his Court has subject matter jurisdiction

over this matter because Devereux is seeking injunctive relief against the TEA for violation of

Devereux’s procedural due process rights under the Constitution.” In its claim against the

Officials, Devereux alleged that “this Court has subject matter jurisdiction over this matter because

Devereux brings this suit against individuals Edward O’Neill and Mike Morath in their official

capacit[ies] for directly contradicting the TEA’s own policies and acting outside the scope of their

authority.” In addition to injunctive relief, Devereux sought “a Declaration that the Defendants’

decision to end Devereux’s eligibility to offer nonpublic residential placements is invalid, a

3 violation of due process, and is beyond the scope of authority provided to the Defendants under

Chapter 7 of the Texas Education Code.” The essence of Devereux’s complaint is that the statutes

and rules on which the TEA relied for its actions do not give the TEA authority to regulate

Devereux’s residential facilities but apply only to Devereux’s educational programs. Devereux

did not allege that any statute was unconstitutional, only that the actions of TEA and the Officials

violated its constitutional rights and exceeded the Officials’ statutory authority.

The TEA and the Officials filed a plea to the jurisdiction, arguing that the court

lacked subject-matter jurisdiction over Devereux’s claims because they are barred by sovereign

immunity and a lack of standing. The trial court denied the plea. The TEA and the Officials

perfected this interlocutory appeal. See Tex. Civ. Prac. & Rem. Code § 51.014(a)(8).

STANDARD OF REVIEW

We review a grant or denial of a plea to the jurisdiction de novo. See Matzen v.

McLane, 659 S.W.3d 381, 388 (Tex. 2021); Texas Dep’t of Parks & Wildlife v. Miranda,

133 S.W.3d 217, 226 (Tex. 2004). A plaintiff must “allege facts that affirmatively demonstrate

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Texas Education Agency Edward O'Neil, Director of Texas Education Agency And Mike Morath, Commissioner of Education v. Devereux Texas League City, Counsel Stack Legal Research, https://law.counselstack.com/opinion/texas-education-agency-edward-oneil-director-of-texas-education-agency-texapp-2023.