University of Texas Rio Grande Valley v. Alfredo Castillo

CourtCourt of Appeals of Texas
DecidedNovember 9, 2023
Docket13-23-00062-CV
StatusPublished

This text of University of Texas Rio Grande Valley v. Alfredo Castillo (University of Texas Rio Grande Valley v. Alfredo Castillo) 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
University of Texas Rio Grande Valley v. Alfredo Castillo, (Tex. Ct. App. 2023).

Opinion

NUMBER 13-23-00062-CV

COURT OF APPEALS

THIRTEENTH DISTRICT OF TEXAS

CORPUS CHRISTI – EDINBURG

UNIVERSITY OF TEXAS RIO GRANDE VALLEY, Appellant,

v.

ALFREDO CASTILLO, Appellee.

On appeal from the County Court at Law No. 5 of Hidalgo County, Texas.

MEMORANDUM OPINION

Before Justices Benavides, Longoria, and Tijerina Memorandum Opinion by Justice Benavides

In this interlocutory appeal from the denial of a plea to the jurisdiction, appellant

University of Texas Rio Grande Valley (UTRGV) contends that appellee Alfredo Castillo

failed to allege certain prima facie elements of his racial discrimination and retaliation claims. UTRGV further argues that Castillo’s claims for civil conspiracy are intentional

torts and thus fall outside the Texas Tort Claims Act’s (TTCA) limited waiver of immunity.

We reverse and remand in part and reverse and render in part.

I. BACKGROUND

According to his first amended petition, Castillo, a Hispanic male, was hired as the

Head Athletic Trainer at UTRGV on December 4, 2017. Castillo served in this position

without incident until UTRGV hired Chasse Conque, a non-Hispanic White male, as its

new Athletic Director in August 2019. Castillo alleges that “[f]rom the beginning, Mr.

Conque’s demeanor and conduct was questionable[,] and he seemed to target Mr.

Castillo with comments that reeked of racial undertones.” Castillo does not provide any

further details about these alleged comments or when they occurred.

Castillo acknowledges friction between the two men arose in March 2020.

Specifically, “Conque did not agree with [his] recommendation to suspend two students

from the Sports Medicine program [or his] proposed COVID-19 reentry plan for student

athletes.” Conque ultimately terminated Castillo’s employment with UTRGV on May 28,

2020.

Castillo alleges that his termination was pretextual and that the actual reason for

his termination was retaliation and racial discrimination. He further alleges that his

termination was “part of a larger unwritten plan or scheme” between Conque, UTRGV’s

president, “and other unknown co-conspirators.” Castillo included claims for civil

conspiracy in his petition based on the underlying claims of retaliation and discrimination.

UTRGV filed a plea to the jurisdiction challenging the sufficiency of Castillo’s first

2 amended petition. UTRGV argued that Castillo failed to plead basic facts that would

establish his retaliation and racial discrimination claims. UTRGV further argued that

Castillo’s civil conspiracy claims are excepted from the TTCA’s waiver of immunity

because civil conspiracy is an intentional tort.

During the ensuing hearing, Castillo’s counsel offered additional details about his

discrimination claim that were not alleged in his live pleading. Rather than discussing

comments that had a “racial undertone,” as alleged in Castillo’s petition, counsel claimed

that Conque told Castillo “point blank: [‘]I have never had to pay somebody like you this

much money.[’]” Castillo’s counsel further alleged that Castillo’s replacement was a non-

Hispanic White person and that “similarly situated employees of UTRGV, who[] were

white, received raises and cost of living adjustments” that Castillo did not receive before

he was terminated. Castillo’s counsel suggested that UTRGV’s arguments were “more

fitting in a summary judgment [motion].” He assured the trial court that “[t]he facts are

there” to prove causation but asked for the opportunity to conduct discovery before “we

get into that.”

UTRGV reiterated that its plea to the jurisdiction was an appropriate vehicle to

challenge the sufficiency of Castillo’s pleadings. UTRGV also noted that its plea had been

pending for more than five months, but Castillo had not taken the opportunity to amend

his pleadings to include these new allegations or to conduct any discovery. The trial court

denied the plea, and this interlocutory appeal ensued. See TEX. CIV. PRAC. & REM. CODE

ANN. § 51.014(a)(8).

3 II. STANDARD OF REVIEW

Subject matter jurisdiction is essential to a court’s authority to decide a case. In re

Abbott, 601 S.W.3d 802, 807 (Tex. 2020) (orig. proceeding) (per curiam) (citing Tex.

Ass’n of Bus. v. Tex. Air Control Bd., 852 S.W.2d 440, 443 (Tex. 1993)). Whether a trial

court has subject matter jurisdiction is a question of law we review de novo. Sampson v.

Univ. of Tex. at Austin, 500 S.W.3d 380, 384 (Tex. 2016).

Sovereign immunity is a common-law doctrine that protects the State and its

agencies from lawsuits for money damages and deprives a trial court of subject matter

jurisdiction over the plaintiff’s claims. Mission Consol. Indep. Sch. Dist. v. Garcia, 253

S.W.3d 653, 655 & n.2 (Tex. 2008) (“Garcia I”). Governmental entities in Texas generally

enjoy immunity from suit unless the Legislature has expressly waived their immunity by

statute. Tex. Nat. Res. Conservation Comm’n v. IT-Davy, 74 S.W.3d 849, 853 (Tex.

2002). This protection extends to state universities, like UTRGV. See Tex. S. Univ. v.

Villarreal, 620 S.W.3d 899, 904 (Tex. 2021).

“A plaintiff has the burden to affirmatively demonstrate the trial court’s jurisdiction.”

Town of Shady Shore v. Swanson, 590 S.W.3d 544, 550 (Tex. 2019) (citing Heckman v.

Williamson County, 369 S.W.3d 137, 150 (Tex. 2012)). Accordingly, when a plaintiff sues

a governmental entity, they must allege facts that fall within a legislative waiver of

immunity. Id. (citing Tex. Dep’t of Transp. v. Jones, 8 S.W.3d 636, 638 (Tex. 1999)). A

governmental defendant may challenge the trial court’s jurisdiction by attacking the

plaintiff’s pleadings, the existence of jurisdictional facts, or both. Alamo Heights Indep.

Sch. Dist. v. Clark, 544 S.W.3d 755, 770 (Tex. 2018).

4 Whether a plaintiff has sufficiently pleaded a waiver of immunity is a question of

law we review de novo. Ryder Integrated Logistics, Inc. v. Fayette County, 453 S.W.3d

922, 927 (Tex. 2015) (per curiam) (citing Tex. Dep’t of Parks & Wildlife v. Miranda, 133

S.W.3d 217, 226 (Tex. 2004)). In conducting our review, we construe the pleadings

liberally and look to the plaintiff’s intent. Miranda, 133 S.W.3d at 226. “If the pleadings do

not contain sufficient facts to affirmatively demonstrate the trial court[’]s jurisdiction but do

not affirmatively demonstrate incurable defects in jurisdiction, the issue is one of pleading

sufficiency and the plaintiffs should be afforded the opportunity to amend.” Id. at 226–27.

On the other hand, “[i]f the pleadings affirmatively negate the existence of jurisdiction,

then a plea to the jurisdiction may be granted without allowing the plaintiffs an opportunity

to amend.” Id. at 227.

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