concept of sovereign immunity (Texas) · Go Syfert
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concept of sovereign immunity in Texas

8 Texas opinions name it 1 courts 2002–2021 1 in the last five years

The cases below were cited by Texas courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (7)

CaseFollowedCited
Lowe v. Texas Tech Universitygreen
tex · 1976 · cited in 2 Texas opinions naming this issue, 2003–2003
2 sentences

2003See Lowe v. Texas Tech Univ ., 540 S.W.2d 297, 298 (Tex. 1976).

2003See Lowe v. Texas Tech Univ., 540 S.W.2d 297, 298 (Tex.1976).

22
Wichita Falls State Hospital v. Taylorgreen
tex · 2003 · cited in 4 Texas opinions naming this issue, 2005–2016
2 sentences

2016To the contrary, in 2003, the Court cited Fernandez favorably in discussing the concept of sovereign immunity, noting there are “rare occasions” when it has found a waiver of sovereign immunity absent ■ the Legislature’s use of “magic words,” such where a statutory provision would be rendered “meaningless unless immunity were waived.” Wichita Falls State Hosp. v. Taylor, 106 S.W.3d 692, 697 (Tex. 2003).

2016The Court noted that this was the case in Fernandez , in which it had held that the provisions of. the anti-retaliation statute defining a state agency as an employer would have “no meaning absent waiver of sovereign immunity.” Id.

14
Familias Unidas, an Unincorporated Association, and Irma Torrez v. Dolph Briscoegreen
ca5 · 1980 · cited in 1 Texas opinions naming this issue, 2021–2021
1 sentence

2021“An employee’s actions taken pursuant to his duties and authorized by state law are considered actions taken by the State,” and courts have held that for whistleblower purposes, the acts of an appointed officer that fall within the authority of his office, even if he misuses that authority, “should be construed as acts of the employing governmental entity.” 13 Housing Auth. of City of El Paso v. Rangel, 131 S.W.3d 542, 547-48 (Tex. App.—El Paso 2004, pet. granted by agr., judgm’t vacated w.r.m.); see also Familias Unidas v. Briscoe, 619 F.2d 391, 403 (5th Cir. 1980) (“Actions for damages again

11
Housing Authority of the City of El Paso v. Rangelgreen
texapp · 2004 · cited in 1 Texas opinions naming this issue, 2021–2021
1 sentence

2021“An employee’s actions taken pursuant to his duties and authorized by state law are considered actions taken by the State,” and courts have held that for whistleblower purposes, the acts of an appointed officer that fall within the authority of his office, even if he misuses that authority, “should be construed as acts of the employing governmental entity.” 13 Housing Auth. of City of El Paso v. Rangel, 131 S.W.3d 542, 547-48 (Tex. App.—El Paso 2004, pet. granted by agr., judgm’t vacated w.r.m.); see also Familias Unidas v. Briscoe, 619 F.2d 391, 403 (5th Cir. 1980) (“Actions for damages again

11
Ashish Patel, Anverali Satani, Nazira Momin, Minaz Chamadia, and Vijay Lakshmi Yogi v. Texas Department of Licensing and Regulationgreen
tex · 2015 · cited in 1 Texas opinions naming this issue, 2021–2021
1 sentence

2021“An employee’s actions taken pursuant to his duties and authorized by state law are considered actions taken by the State,” and courts have held that for whistleblower purposes, the acts of an appointed officer that fall within the authority of his office, even if he misuses that authority, “should be construed as acts of the employing governmental entity.” 13 Housing Auth. of City of El Paso v. Rangel, 131 S.W.3d 542, 547-48 (Tex. App.—El Paso 2004, pet. granted by agr., judgm’t vacated w.r.m.); see also Familias Unidas v. Briscoe, 619 F.2d 391, 403 (5th Cir. 1980) (“Actions for damages again

11
Travis County v. Pelzel & Associates, Inc.red
tex · 2002 · cited in 1 Texas opinions naming this issue, 2002–2002
1 sentence

2002See, e.g., IT-Davy, 74 S.W.3d at 856-57 (rejecting argument for waiver by conduct in contract case where State had fully accepted benefits of contract); see also Travis County v. Pelzel & Assocs., Inc., 77 S.W.3d 246, 251-52 , 45 Tex. Sup. Ct. J. 623 , 626-27 (2002) (rejecting waiver-by-conduct exception to sovereign immunity where county invoked contract’s liquidated damages provision).

11
Texas Natural Resource Conservation Commission v. IT-Davygreen
tex · 2002 · cited in 1 Texas opinions naming this issue, 2002–2002
1 sentence

2002See, e.g., IT-Davy, 74 S.W.3d at 856-57 (rejecting argument for waiver by conduct in contract case where State had fully accepted benefits of contract); see also Travis County v. Pelzel & Assocs., Inc., 77 S.W.3d 246, 251-52 , 45 Tex. Sup. Ct. J. 623 , 626-27 (2002) (rejecting waiver-by-conduct exception to sovereign immunity where county invoked contract’s liquidated damages provision).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Texas. Read the followed side critically anyway.

Where else courts name it

TX 8 (2002–2021) TN 8 (1979–2024) KY 8 (2001–2026) OK 5 (1976–2014) IL 5 (1978–2016) NC 4 (2018–2022) OH 4 (1996–2007) CA 4 (1994–2021) WY 3 (1959–2024) RI 3 (1998–2017) SD 3 (1980–1990) NY 3 (1961–1997) LA 2 (1973–1990) PA 2 (1984–2013) MD 2 (1966–1998) CO 2 (2002–2010) FL 2 (1980–2000) WI 2 (1979–2020) AZ 2 (1979–1997)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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