Victor H. Tamayo v. Sheriff Omar Lucio, in His Official Capacity

CourtCourt of Appeals of Texas
DecidedJuly 18, 2013
Docket13-11-00746-CV
StatusPublished

This text of Victor H. Tamayo v. Sheriff Omar Lucio, in His Official Capacity (Victor H. Tamayo v. Sheriff Omar Lucio, in His Official Capacity) 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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Victor H. Tamayo v. Sheriff Omar Lucio, in His Official Capacity, (Tex. Ct. App. 2013).

Opinion

NUMBER 13-11-00746-CV

COURT OF APPEALS

THIRTEENTH DISTRICT OF TEXAS

CORPUS CHRISTI - EDINBURG

VICTOR H. TAMAYO, Appellant,

v.

SHERIFF OMAR LUCIO, IN HIS OFFICIAL CAPACITY, Appellee.

On appeal from the 138th District Court of Cameron County, Texas.

MEMORANDUM OPINION Before Chief Justice Valdez and Justices Benavides and Perkes Memorandum Opinion by Justice Benavides A trial court dismissed appellant Victor Tamayo’s case by granting a plea to the

jurisdiction filed by the appellee, Cameron County Sheriff Omar Lucio in his official

capacity. In two issues, Tamayo argues that: (1) governmental immunity did not bar his suit because he alleged a statutory violation and was not seeking monetary

damages, and (2) the Cameron County Sheriff was the proper defendant in his suit

alleging an ultra vires act. We affirm, in part, and reverse and remand, in part.

I. BACKGROUND

Tamayo was a licensed and commissioned peace officer for the State of Texas.

After Tamayo worked for several municipal police departments, then-Sheriff Conrado

Cantu commissioned Tamayo as a Sheriff’s Deputy for Cameron County in 2001. With

this commission, Tamayo received a badge from the Cameron County Sheriff’s

Department that identified him as a full-time peace officer. In 2005, Tamayo was

re-appointed by the current Cameron County Sheriff, Omar Lucio, as a Deputy Bailiff

“with full power and authority to perform all the acts and duties required. . . .” From

2005 to 2009, Tamayo worked as a bailiff in the 107th Judicial District Court for the

Honorable Benjamin Euresti, Jr. His job responsibilities included screening people who

entered the Cameron County Courthouse and providing additional security in Judge

Euresti’s courtroom. Of note, at this time in Cameron County, bailiffs’ paychecks were

issued through the county’s “Courthouse Security Department” and not through the

Sheriff’s Department.

Tamayo alleges that, on May 8, 2009, he issued a written reprimand for

insubordination to fellow Deputy/Bailiff Elizabeth Avitia. Deputy Avitia then complained

about Tamayo’s reprimand “upstairs” at the Cameron County courthouse. On May 11,

2009, Judge Euresti terminated Tamayo’s employment with the following letter:

2 As it may evidence, your services are no longer required and you are to turn all of your Cameron County issued equipment. Therefore, you are relieved from your duties effective today May 11, 2009 instanter.

After receiving this letter of termination, Tamayo appealed the decision to Sheriff

Lucio. Tamayo asserted that, as a peace officer, he was entitled to the protections of

chapter 614 of the Texas Government Code. TEX. GOV’T CODE ANN. § 614.001–.104

(West 2004 & Supp. 2011). Chapter 614 sets forth the procedures by which persons

such as peace officers and firefighters can be disciplined and/or terminated. According

to Tamayo’s pleadings, Sheriff Lucio denied the appeal and eventually submitted an “F-5

Report of Separation of License” to the Texas Commission on Law Enforcement,

reporting that Tamayo’s commission was honorably discharged. Lucio’s denial and

subsequent actions, Tamayo claims, constituted an “ultra vires ratification” of Judge

Euresti’s termination.

Tamayo then appealed to the Cameron County Civil Service Commission, which

dismissed his appeal for lack of jurisdiction. Bailiffs were not covered by the Civil

Service Commission at the time.1 The Civil Service Commission explained that it could

not consider his complaint because he was not an employee of the Sheriff’s Department,

but rather an at-will employee of the Cameron County Courthouse Security Department.

Tamayo then filed suit, requesting: (1) a declaratory judgment, (2) a request for

mandamus, and (3) a finding of wrongful termination and retaliation.2 Although his

1 Cameron County has since modified this policy to include bailiffs in their civil service commission. 2 We refer to Tamayo’s live pleading, entitled “Plaintiff’s Fourth Amended Petition.”

3 lawsuit was initially filed against the Cameron County Civil Service Commission, he later

dismissed his claims against this entity and added Sheriff Lucio in his official capacity as

Cameron County Sheriff. Tamayo argued that under chapter 614, he could not be

terminated without being given written notice of the charges against him, which must be

signed by the person making the complaint. See id. § 614.022. The complaint must

also be fully investigated and there must be evidence to prove the alleged misconduct.

Id. § 614.023(c).

Sheriff Lucio filed a plea to the jurisdiction, claiming that Tamayo was an at-will

employee employed by the Cameron County District Courthouse Security Department,

not a peace officer under the supervision of the Sheriff’s Department. As a courthouse

employee, Sheriff Lucio averred, Tamayo was not covered by chapter 614; thus, the

sheriff’s department had no duty to abide by those provisions. After a hearing, the trial

court granted Sheriff Lucio’s plea to the jurisdiction, thus dismissing Tamayo’s claims.

Tamayo appealed.

II. LAW REGARDING CHAPTER 614

Chapter 614 sets forth the procedures by which peace officers and firefighters in

Texas can be disciplined and/or terminated. TEX. GOV’T CODE ANN. § 614.001–.104.

This chapter defines employers as any “governmental entity that employs or appoints a

peace officer or fire fighter . . . .” Id. § 614.001(1). The statute applies to complaints

against any “peace officer under Article 2.12, Code of Criminal Procedure, or other law

who is appointed or employed by a political subdivision of this state.” Id. §

614.021(a)(3); see TEX. CODE CRIM. PROC. ANN. art. 2.12 (West Supp. 2011). Under

4 chapter 614, peace officers and firefighters are “entitled to an investigation and to

receive a copy of the written complaint before being disciplined or terminated.” See

Graves v. Mack, 246 S.W.3d 704, 706 (Tex. App.—Houston [14th Dist.] 2007, no pet);

see also TEX. GOV’T CODE ANN § 614.023. The complaint must be in writing and signed

by the person making the complaint. TEX. GOV’T CODE ANN. § 614.022. Further,

before being terminated, the complaint must be fully investigated and there must be

“evidence to prove the allegation of misconduct.” Id. § 614.023(c).

III. PLEA TO THE JURISDICTION

A. Applicable Law

1. Plea to the Jurisdiction

A plea to the jurisdiction is a dilatory plea; its purpose is “to defeat a cause of

action without regard to whether the claims asserted have merit.” Bland Indep. Sch.

Dist. v. Blue, 34 S.W.3d 547, 554 (Tex. 2000). The plea challenges the trial court's

authority to determine the subject matter of a pleaded cause of action. Tex. State

Employees Union/CWA Local 6184 v. Tex. Workforce Comm'n, 16 S.W.3d 61, 65 (Tex.

App.—Austin 2000, no pet.). The existence of subject-matter jurisdiction is a question

of law; thus, we review de novo the trial court's ruling on a plea to the jurisdiction. Id.

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