West Houston Charter School Alliance v. Jean Pickering

CourtCourt of Appeals of Texas
DecidedAugust 18, 2011
Docket01-10-00289-CV
StatusPublished

This text of West Houston Charter School Alliance v. Jean Pickering (West Houston Charter School Alliance v. Jean Pickering) 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
West Houston Charter School Alliance v. Jean Pickering, (Tex. Ct. App. 2011).

Opinion

Opinion issued August 18, 2011.

In The

Court of Appeals

For The

First District of Texas

————————————

NO. 01-10-00289-CV

———————————

West Houston ChaRter School Alliance, Appellant

V.

Jean Pickering, Appellee

On Appeal from the 125th District Court

Harris County, Texas

Trial Court Case No. 2009-64131

MEMORANDUM OPINION

          This interlocutory appeal from the trial court’s denial of a school’s plea to the jurisdiction arises out of Jean Pickering’s claim that the school demoted and constructively discharged her in retaliation for reporting that the school board had violated the Texas Open Meetings Act. Because we conclude that Pickering failed to initiate the school’s grievance procedure before filing her whistleblower action, we reverse the trial court’s denial of the school’s plea to the jurisdiction and dismiss Pickering’s claims against the school for lack of jurisdiction.

Background

          Pickering, the school’s administrator, filed a suit against West Houston Charter School Alliance and several of its board members, asserting that the school violated the Texas Whistleblower Act by retaliating against her after she reported to the Texas Education Agency that the board was holding meetings in violation of the Texas Open Meetings Act.[1] See Tex. Gov’t Code Ann. § 554.002(a) (West 2004) (prohibiting governmental entity from taking adverse personnel action against public employee who, in good faith, reports violation of law by employer or another public employee to appropriate law enforcement authority); id. § 551.001–.146 (governing open meeting requirements for governmental bodies). Pickering alleged two incidents of retaliatory conduct. First, the school board placed her on “a corrective plan at a final warning stage,” which Pickering asserted stripped her of her responsibilities and was designed to serve as a demotion. The school board presented the corrective action plan to Pickering at a July 9, 2009 board meeting.  Second, Pickering alleged that the board members damaged her reputation in the community and forced her to resign on August 3, 2009, which constituted a constructive discharge.

After Pickering initiated this action, the school filed a plea to the jurisdiction, contending that Pickering failed to initiate a grievance under the school’s grievance procedure before filing suit. Pickering responded that the school’s grievance procedure did not apply to her and that she had appealed the school’s actions by a letter her attorney sent to the school board on July 22, “seeking a fundamentally fair hearing on the matter.”

The trial court denied the school’s plea to the jurisdiction. In its order, the trial court stated:

All parties having appeared in open court by and through their attorneys and all parties having agreed on the record that plaintiff by and through her counsel did, on or about July 22, 2009, within 90 days of the claimed adverse employment action[,] g[i]ve written notice to the Defendant’s Board of Trustees that the Plaintiff “appeal[ed] the decision to place her on a professional growth plan and specifically request[ed] that as part of that appeal, she be afforded a due process, meaningful hearing pursuant to the mandates of Ferguson v. Thomas, before an impartial and academically oriented hearing officer or panel.”

Having heard arguments of counsel and considered the documents filed herein, the Court is of the opinion and finds that Plaintiff initiated Defendant’s appeal procedures, or that a fact dispute exists as to whether Plaintiff’s actions initiated Defendant’s appeal procedures, and that Defendant’s Plea to the Jurisdiction is not established as a matter of law.

This interlocutory appeal followed. See Tex. Civ. Prac. & Rem. Code Ann.             § 51.014(a)(8) (authorizing interlocutory appeal from the grant or denial of a governmental unit’s plea to the jurisdiction); LTTS Charter Sch., Inc. v. C2 Constr., Inc., No. 09-0794, 2011 WL 2420204, at *5–6 (Tex. June 17, 2011) (holding that an open-enrollment charter school is a “governmental unit” for purposes of section 51.014(a)(8)).[2]

Standard of Review

The school’s plea to the jurisdiction is a dilatory plea that seeks dismissal of Pickering’s claims against it for lack of subject-matter jurisdiction. Bland Indep. Sch. Dist. v. Blue, 34 S.W.3d 547, 554 (Tex. 2000); Univ. of Houston v. Barth, 178 S.W.3d 157, 160–61 (Tex. App.—Houston [1st Dist.] 2005, no pet.). Subject-matter jurisdiction is essential to the authority of a court to decide a case. Tex. Ass’n of Bus. v. Tex. Air Control Bd., 852 S.W.2d 440, 443 (Tex. 1993); Barth, 178 S.W.3d at 161. The existence of subject-matter jurisdiction is a question of law that we review de novo. State Dep’t of Hwys. & Pub. Transp. v. Gonzalez, 82 S.W.3d 322, 327 (Tex. 2002); Kamel v. Univ. of Tex. Health Sci. Ctr. at Houston, 333 S.W.3d 676, 681 (Tex. App.—Houston [1st Dist.] 2010, pet. denied).

When a plea to the jurisdiction challenges the existence of jurisdictional facts, we apply a standard of review that mirrors the standard applicable to traditional summary judgments. Tex.

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West Houston Charter School Alliance v. Jean Pickering, Counsel Stack Legal Research, https://law.counselstack.com/opinion/west-houston-charter-school-alliance-v-jean-picker-texapp-2011.