Webb Consolidated Independent School District v. Robert Marshall and Amy Marshall

CourtTexas Supreme Court
DecidedApril 24, 2026
Docket24-0339
StatusPublished
AuthorLehrmann

This text of Webb Consolidated Independent School District v. Robert Marshall and Amy Marshall (Webb Consolidated Independent School District v. Robert Marshall and Amy Marshall) is published on Counsel Stack Legal Research, covering Texas Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Webb Consolidated Independent School District v. Robert Marshall and Amy Marshall, (Tex. 2026).

Opinions

Supreme Court of Texas ══════════ No. 24-0339 ══════════

Webb Consolidated Independent School District, Petitioner,

v.

Robert Marshall and Amy Marshall, Respondents

═══════════════════════════════════════ On Petition for Review from the Court of Appeals for the Fourth District of Texas ═══════════════════════════════════════

Argued October 8, 2025

JUSTICE LEHRMANN delivered the opinion of the Court.

JUSTICE HAWKINS filed a concurring opinion, in which Justice Young and Justice Sullivan joined.

The Texas Education Code recognizes that school-board members acting in their official capacities have “an inherent right of access to information, documents, and records maintained by the [school] district.” TEX. EDUC. CODE § 11.1512(c). The Code provides those board members with the opportunity to sue for injunctive relief when the district does not provide them with requested information and to recover attorney’s fees if they “prevail[]” in such a suit. Id. § 11.1512(c-2). In this case, two school-board members sued Webb Consolidated Independent School District under Section 11.1512 and obtained a temporary injunction ordering the District to produce some of the requested information and documents. Before the case proceeded to trial, however, the members’ terms on the board expired. The primary issue here is whether the board members nevertheless prevailed under the statute by obtaining injunctive relief, thereby entitling them to recover attorney’s fees. We hold that they did. Although a party generally does not “prevail” for fee purposes by obtaining a temporary injunction, the trial court’s order effectively granted the board members the final relief Section 11.1512 authorizes: an injunction requiring the District to timely produce requested information to which the members have an inherent right of access. Additionally, we hold that the board members were not required to exhaust their administrative remedies before filing suit because Section 11.1512(c-2) creates an exception to the general exhaustion requirement. We therefore affirm the court of appeals’ judgment.

I. Background

Robert and Amy Marshall were members of the board of trustees of Webb Consolidated Independent School District. On May 16, 2020, the Marshalls requested information from the District regarding agenda

2 items for an upcoming board meeting.1 The following month, the Marshalls sued the District for injunctive relief under Texas Education

1 In the May 16 request, quoted below, the Marshalls sought information and documents regarding six items: 1. Who is the architect for projects [sic] and why is he not signing certificates for payment AIA Document G702-1992? 2. Agenda item #7. Discussion regarding 2020-2021 District Calendar and Master Schedule. A. Where are the Wind Tech Training Classes? 3. Agenda Item #12. Discussion and Possible action to approve _______ as Construction Management Consultants for building Elementary School to increase enrollment. A. Is the board planning on building a new Elementary School? B. Where is this school going to be built? C. How is building a new school going to increase enrollment? 4. Agenda Item #13. Presentation by Financial advisor to discuss a Cash Defeasance scenario. A. Who is the Financial advisor you are referring to? B. What is the Cash Defeasance scenario? 5. Agenda Item #15. Discussion and possible action to accept the recommendation of the Superintendent to hire the following Classroom Teachers for 2020-2021. Secondary Teacher, Elementary Teacher, and Middle School Teacher. A. We would like to know who you are recommending? B. What are their credentials? C. How much experience do they have as an educator? D. Are their certifications current with all state requirements? E. Do they have emergency permit or a standard certification?

3 Code Section 11.1512(c-2), alleging that the District had failed to turn over the information. The Marshalls also sought an award of costs and attorney’s fees. See id. § 11.1512(c-2) (“A member who prevails in a suit under this subsection is entitled to recover court costs and reasonable attorney’s fees.”). On September 15, 2020, the trial court issued a “Temporary Injunction Order” finding, among other things, that the Marshalls “have made . . . a proper request pursuant to” Section 11.1512, that “harm is imminent because [the Marshalls] will be unable to properly address the issues before the Board,” and that injunctive relief “is specifically authorized by” Section 11.1512(c-2). The court ordered the District to produce to the [Marshalls] the following documents and information pertaining to the May 19, 2020 Board Meeting: 1. Information and documentation regarding the contractor’s application for payment as to [five specific construction] projects[;] .... 2. Construction Management Consultants for building Elementary School; 3. Certification information on the Superintendent recommended Classroom Teachers; 4. Extension of Administrator(s) Term Contracts including [the] Superintendent . . . i.e. 2019 evaluation.

6. Agenda Item 17. Discussion and possible action regarding the extension of Administrator(s) Term Contracts. A. Why are we extending the Superintendent Heriberto Gonzalez [contract] without his evaluation in the last 15 months?

4 The order concluded by requiring the District to produce the information within twenty days of the order’s execution. The District did not appeal the order. Amy Marshall’s term on the board expired in November 2020. The following month, the Marshalls amended their petition to seek injunctive relief regarding the District’s alleged failure to comply with five additional requests for documents and information that Robert Marshall had made in 2019 and 2020 in his capacity as a board member. They later filed a supplemental petition to add claims related to four other requests from 2019. Meanwhile, the Marshalls were pursuing a separate administrative proceeding against the District stemming from the board’s vote to censure them at a September 2019 board meeting. One of the claims asserted in that proceeding was that the Marshalls had requested documents supporting their censure on multiple occasions and that the District violated Section 11.1512 by failing to provide them. In May 2021, the Commissioner of Education dismissed that claim for lack of jurisdiction.2 The Marshalls did not seek review of the Commissioner’s decision but instead added the claim to their pending suit as part of the above-referenced supplemental petition.3

2 The Commissioner specifically determined that (1) the Marshalls “failed to exhaust this issue” because they did not include it in their grievance against the District and (2) their pleadings affirmatively negated the claim by asserting that the District had no documents supporting their censure. 3 The Marshalls filed their supplemental petition in April 2021, after

the administrative law judge issued a proposal for decision in the administrative proceeding but before the Commissioner issued a final decision.

5 The Marshalls then filed a motion to compel, complaining about the District’s responses to numerous discovery requests. The District filed a plea to the jurisdiction and motion for summary judgment, arguing that (1) the Marshalls failed to exhaust their administrative remedies, (2) Amy Marshall’s claims were moot because she was no longer a school-board member, and (3) the District had already provided the Marshalls with all responsive documents that it maintained.4 The trial court denied the District’s motions, and the District appealed that order. See TEX. CIV. PRAC. & REM. CODE § 51.014(a)(8) (authorizing an interlocutory appeal of an order that grants or denies a plea to the jurisdiction by a governmental unit).

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