the City of Paris, Texas v. Bobby Floyd

CourtCourt of Appeals of Texas
DecidedOctober 26, 2004
Docket06-03-00160-CV
StatusPublished

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the City of Paris, Texas v. Bobby Floyd, (Tex. Ct. App. 2004).

Opinion



In The

Court of Appeals

Sixth Appellate District of Texas at Texarkana


______________________________


No. 06-03-00160-CV



THE CITY OF PARIS, TEXAS, Appellant

V.

BOBBY FLOYD AND L. C. BROWN CONSTRUCTION, Appellees




On Appeal from the 6th Judicial District Court

Lamar County, Texas

Trial Court No. 70956





Before Morriss, C.J., Ross and Carter, JJ.

Opinion by Chief Justice Morriss



O P I N I O N

            All agree that extraordinarily heavy rainfall overwhelmed part of the City of Paris sewer system under construction—and its lift station containing motor-driven pumps—near Bobby Floyd's rental house occupied by tenants, Shawn and Amy Philpot. As a result, raw sewage flowed into the house, along with rainwater and silt.

            Floyd sued L. C. Brown Construction and the City of Paris, alleging that an inadequately supervised Brown negligently failed to close its excavation and to install certain components in the system; that the City failed to properly operate, use, and maintain the system, including the motor-driven pumps in the lift station; that the City failed to use sufficient equipment in the system; and that the City negligently misused the lift station and its motor-driven pumps to attempt to transport storm waters, rather than just the sewage for which they were designed. The Philpots intervened as parties plaintiff, with similar allegations. The trial court denied the City's request that the claims against it be dismissed for want of jurisdiction based on sovereign immunity.

            The City asks this Court to dismiss the claims against it based on its plea to the jurisdiction because (1) it is not liable vicariously for Brown's actions, because Brown was an independent contractor as set out by the written contract, and there is no evidence of actions by Brown and the City which would allow a finding of the right of the City to control Brown's activities; (2) sovereign immunity was not waived because plaintiffs allege only a "non-use" of motor-driven equipment, not an "operation or use" of that equipment; (3) no City employee could be liable because none could have stopped the flooding from occurring in the Floyd house; and (4) no City employee was identified in the pleadings. We reject the City's arguments and affirm the trial court's denial of the City's requested dismissal. We address the City's arguments in turn, but first we set out relevant law on sovereign immunity and how we are to review motions to dismiss which assert sovereign immunity.

Sovereign Immunity and Appellate Review of Pleas to the Jurisdiction

            A governmental unit is not liable for the torts of its officers or agents without a constitutional or statutory provision waiving sovereign immunity. Dallas Co. Mental Health & Mental Retardation v. Bossley, 968 S.W.2d 339, 341 (Tex. 1998). In a limited waiver of sovereign immunity arguably applicable   here,   the   Texas   Tort   Claims   Act   provides  that  a  governmental  entity  is  liable  if "(A) . . . property damage . . . arises from the operation or use of . . . motor-driven equipment; and (B) the employee would be personally liable to the claimant according to Texas law. . . ." Tex. Civ. Prac. & Rem. Code Ann. § 101.021(1) (Vernon 1997).

            Unless sovereign immunity has been waived, the immunity defeats the trial court's jurisdiction, and a plea to the jurisdiction is in order. Harris County v. Sykes, 136 S.W.3d 635, 638 (Tex. 2004); Tex. Dep't of Parks & Wildlife v. Miranda, 133 S.W.3d 217, 225–226 (Tex. 2004). The petitioner in a lawsuit must allege facts that affirmatively demonstrate the court's jurisdiction to hear the cause of action. Tex. Ass'n of Bus. v. Tex. Air Control Bd., 852 S.W.2d 440, 446 (Tex. 1993). Whether a court has subject matter jurisdiction is a question of law. Tex. Natural Res. Conservation Comm'n v. IT-Davy, 74 S.W.3d 849, 855 (Tex. 2002). Whether a pleader has alleged facts that affirmatively demonstrate a trial court's subject matter jurisdiction is a question of law reviewed de novo. In some cases, however, disputed evidence of jurisdictional facts may require resolution by the finder of fact. Miranda, 133 S.W.3d at 226.

            The Texas Supreme Court in Miranda set out how we should review trial court rulings on pleas to the jurisdiction, and our review is to differ depending on whether the plea challenges the pleadings or the evidence. See id. at 226–28.

            If the plea challenges the pleadings, we determine whether the pleading alleges facts affirmatively demonstrating the court's jurisdiction, and in that pursuit we construe the pleadings liberally in favor of the pleader. If the pleadings insufficiently demonstrate jurisdiction, but could be made sufficient by amendment, an opportunity to amend should be allowed. On the other hand, if the pleadings affirmatively negate jurisdiction, dismissal is proper without the opportunity to amend. Id.

            If the plea challenges the existence of jurisdictional facts, there are three alternatives. First, the trial court has discretion to determine whether a jurisdictional disposition should be made at a preliminary hearing or later, after the case has been more fully developed. Second, if the evidence is conclusive or uncontroverted, the plea should be ruled on as a matter of law. Third, if there is a fact issue, the preliminary plea is properly denied. Id.

1. Brown's Independence was not Conclusively Proven

            The City first argues that Brown was an independent contractor, as set out by the written contract, and that there is no evidence of control exerted by the City sufficient to support a finding that, notwithstanding the contract, the City had the right to control Brown's activities.  

            The test for determining whether an employment or an independent contractor relationship exists is whether the purported employer has a right to control the details of the person's work. Shell Oil Co. v. Khan, 138 S.W.3d 288 (Tex. 2004); St. Joseph Hosp. v. Wolff, 94 S.W.3d 513, 542 (Tex. 2003); INA of Tex. v. Torres, 808 S.W.2d 291, 293 (Tex.

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Related

Texas Department of Parks & Wildlife v. Miranda
133 S.W.3d 217 (Texas Supreme Court, 2004)
Harris County v. Sykes
136 S.W.3d 635 (Texas Supreme Court, 2004)
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138 S.W.3d 288 (Texas Supreme Court, 2004)
Texas Natural Resource Conservation Commission v. IT-Davy
74 S.W.3d 849 (Texas Supreme Court, 2002)
City of Saginaw v. Carter
996 S.W.2d 1 (Court of Appeals of Texas, 1999)
Texas Ass'n of Business v. Texas Air Control Board
852 S.W.2d 440 (Texas Supreme Court, 1993)
Dallas Cty. Mental Health and Mental Retardation v. Bossley
968 S.W.2d 339 (Texas Supreme Court, 1998)
St. Joseph Hospital v. Wolff
94 S.W.3d 513 (Texas Supreme Court, 2002)
Farrell v. Greater Houston Transportation Co.
908 S.W.2d 1 (Court of Appeals of Texas, 1995)
Newspapers, Inc. v. Love
380 S.W.2d 582 (Texas Supreme Court, 1964)
INA of Texas v. Torres
808 S.W.2d 291 (Court of Appeals of Texas, 1991)
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