William C. Morrow, Jimmy Smith, Mike Bradford, Juluis Brooks and Randy Prude v. Truckload Fireworks, Inc.

CourtCourt of Appeals of Texas
DecidedMarch 22, 2007
Docket11-06-00197-CV
StatusPublished

This text of William C. Morrow, Jimmy Smith, Mike Bradford, Juluis Brooks and Randy Prude v. Truckload Fireworks, Inc. (William C. Morrow, Jimmy Smith, Mike Bradford, Juluis Brooks and Randy Prude v. Truckload Fireworks, Inc.) 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
William C. Morrow, Jimmy Smith, Mike Bradford, Juluis Brooks and Randy Prude v. Truckload Fireworks, Inc., (Tex. Ct. App. 2007).

Opinion

Opinion filed March 22, 2007

Opinion filed March 22, 2007

                                                                        In The

    Eleventh Court of Appeals

                                                                 ____________

                                                          No. 11-06-00197-CV

                                                    __________

            WILLIAM C. MORROW, JIMMY SMITH, MIKE BRADFORD,

                    JULUIS BROOKS, AND RANDY PRUDE, Appellants

                                                             V.

                           TRUCKLOAD FIREWORKS, INC., Appellee

                                        On Appeal from the 142nd District Court

                                                        Midland County, Texas

                                                Trial Court Cause No. CV-45,560

                                                                   O P I N I O N

The trial court entered a temporary restraining order enjoining enforcement of Midland County=s Declaration of Disaster and Executive Order.  Midland County[1] appeals the trial court=s decision to deny its motion to dismiss for lack of jurisdiction.  We vacate the trial court=s injunction and remand.


                                                              I. Background Facts

On June 15, 2006, Midland County Judge William C. Morrow issued a Declaration of Disaster for Midland County and an Executive Order banning the outdoor use of all combustibles, including fireworks, in Midland County.[2]  Authorized public displays of fireworks were excluded from the ban.  A violation of the executive order was a Class C misdemeanor.  Midland County withdrew the declaration and executive order on June 23, 2006, because of recent rain and a favorable weather forecast, but on June 27, 2006, a new disaster declaration and executive order were executed.  The June 27 declaration and order were identical to the June 15 declaration and order and will be referenced in this opinion as the Afireworks ban.@

Truckload Fireworks, Inc. filed suit after the execution of the original declaration and executive order and requested injunctive relief.[3]  Midland County filed a motion to dismiss for lack of jurisdiction.  The trial court took Midland County=s motion under advisement, conducted an evidentiary hearing, and granted Truckload=s request for injunctive relief.  The trial court did not expressly rule on the motion to dismiss but, by granting Truckload affirmative relief, denied the motion by implication.

                                               II. Issues

Midland County contends that the trial court erred by not dismissing Truckload=s suit for lack of subject-matter jurisdiction.[4]  Before we address the trial court=s jurisdiction, however, we must first determine our own because the fireworks ban has expired.

                                             III.  Has this Controversy Become Moot? 


Counsel acknowledged during oral argument that the fireworks ban has expired.  Because the injunction merely prohibited Midland County from enforcing the ban, its expiration makes this controversy moot.  See Murphy v. Hunt, 455 U.S. 478, 481 (1982) (a case becomes moot when the issues are no longer live or when the parties lack a legally cognizable interest in the outcome).  If a case becomes moot, the parties lose standing to maintain their claims.  Williams v. Lara, 52 S.W.3d 171, 184 (Tex. 2001).  Accordingly, this court asked counsel why the case should not be dismissed.  Midland County responded that this suit falls under the Acapable of repetition, yet evading review@ exception to the mootness doctrine.  Midland County has since provided this court with a letter brief containing citations to several cases discussing the doctrine.  Truckload has advised the court that it has no other authority, but has not advocated a position on the mootness issue.

The capable of repetition, yet evading review exception applies infrequently.  See City of Los Angeles v. Lyons, 461 U.S. 95, 109 (1983) (the doctrine is exceptional and applies only when the plaintiff can make a reasonable showing that he will again be subjected to the alleged illegality).  To invoke the exception, a party must prove that the challenged action was too short in duration to be litigated fully before the action ceased or expired and that a reasonable expectation exists that the same complaining party will be subjected to the same action again.  Murphy, 455 U.S. at 482.

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William C. Morrow, Jimmy Smith, Mike Bradford, Juluis Brooks and Randy Prude v. Truckload Fireworks, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/william-c-morrow-jimmy-smith-mike-bradford-juluis--texapp-2007.