Tex. Codes » Education Code · TITLE 2. PUBLIC EDUCATION · SUBTITLE D. EDUCATORS AND SCHOOL DISTRICT EMPLOYEES AND VOLUNTEERS · CHAPTER 22. SCHOOL DISTRICT EMPLOYEES AND VOLUNTEERS
Texas Codes

Tex. Educ. Code § 22.051 (2026)

Definition; Other Immunity

✓ current as of May 2026
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Sec. 22.051. DEFINITION; OTHER IMMUNITY. (a) In this subchapter, "professional employee of a school district" includes:

(1) a superintendent, principal, teacher, including a substitute teacher, supervisor, social worker, school counselor, nurse, and teacher's aide employed by a school district;

(2) a teacher employed by a company that contracts with a school district to provide the teacher's services to the district;

(3) a student in an education preparation program participating in a field experience or internship;

(4) a school bus driver certified in accordance with standards and qualifications adopted by the Department of Public Safety of the State of Texas;

(5) a member of the board of trustees of an independent school district; and

(6) any other person employed by a school district whose employment requires certification and the exercise of discretion.

(b) The statutory immunity provided by this subchapter is in addition to and does not preempt the common law doctrine of official and governmental immunity.

Added by Acts 2003, 78th Leg., ch. 204, Sec. 15.01, eff. Sept. 1, 2003; Acts 2003, 78th Leg., ch. 1197, Sec. 1, eff. Sept. 1, 2003.

Amended by:

Acts 2013, 83rd Leg., R.S., Ch. 443 (S.B. 715), Sec. 17, eff. June 14, 2013.

Notes of Decisions
Cited in 53 cases (3 in the last 5 years), 1996–2025 · leading case: Davis v. Educ. Serv. Ctr., 62 S.W.3d 890 (Tex. App. 2001).
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Davis v. Educ. Serv. Ctr., 62 S.W.3d 890 (Tex. App. 2001). · cites it 5× “006 of the Texas Education Code, which grants employees and volunteers of a regional education service center the same immunity from liability as school district employees and volunteers.”
Collins v. Ison-Newsome, 73 S.W.3d 178 (Tex. 2001). · cites it 5× “See Tex. Educ.Code § 22.051(a). However, we cannot reach the merits because we conclude that we do not have jurisdiction over this interlocutory appeal.”
Calvin Walker v. Beaumont Indep Sch. Dist, 938 F.3d 724 (5th Cir. 2019). “TEX. EDUC. CODE § 22.051 (definition of professional employee of school district includes member of the board of trustees of an independent school district); TEX.”
Gil Ramirez Grp., L.L.C. v. Houston Indep. Sch. Dist., 786 F.3d 400 (5th Cir. 2015). · cites it 3× “Provisions of the Texas Education Code define a school board trustee as an employee, Tex. Educ. Code § 22.051, 19 and grant immunity to “employees” for “any act that is incident to or within the scope of the duties of the employee’s position .”
Choctaw Props., L.L.C. v. Aledo I.S.D., 127 S.W.3d 235 (Tex. App. 2003). · cites it 2× “Laws 2207 , 2283 (amended 2003) (current version at Tex. Educ.Code Ann. § 22.051(a)(1) (Vernon Supp.”
Kobza v. Kutac, 109 S.W.3d 89 (Tex. App. 2003). · cites it 4× “See Tex. Educ.Code Ann. § 22.051 (West 1996).”
In Re Hinterlong, 109 S.W.3d 611 (Tex. App. 2003). · cites it 2× “051(a) of the Education Code are established); see also Tex. Educ. Code Ann. § 22.051 (a) (Vernon 1996) (stating that professional school district employees are not personally hable for actions incident to or within the scope of duties performed that involve the exercise of…”
Foster v. Estrada, 974 S.W.2d 751 (Tex. App. 1998). · cites it 6× “TEX. EDUC.CODE ANN. § 22.051 (Vernon 1996).”
Enriquez v. Khouri, 13 S.W.3d 458 (Tex. App. 2000). · cites it 4× “7 Immunity under the Texas Education Code Texas Education Code Section 22.051 provides immunity for professional employees of school districts, stating that: (a) A professional employee of a school district is not personally liable for any act that is incident to or within the…”
Myers v. Doe, 52 S.W.3d 391 (Tex. App. 2001). · cites it 3× “Tex.Educ. Code Ann. § 22.051(a) (Vernon 1996).”
Deaver v. Bridges, 47 S.W.3d 549 (Tex. App. 2001). · cites it 2× “ANALYSIS Texas Education Code section 22.051 provides immunity for professional employees of school districts, stating that: (a) A professional employee of a school district is not personally liable for any act that is incident to or within the scope of the duties of the…”
Morris v. Dearborne, 181 F.3d 657 (5th Cir. 1999). “Tex. Educ.Code § 22.051(a). The parties do not dispute that Dearborne was an employee of the school district or that she was acting within the scope of her duties.”
Show all 53 citing cases →
— Tex. Educ. Code § 22.051(a) — 21 cases
Collins v. Ison-Newsome, 73 S.W.3d 178 (Tex. 2001). “See Tex. Educ.Code § 22.051(a). However, we cannot reach the merits because we conclude that we do not have jurisdiction over this interlocutory appeal.”
Davis v. Educ. Serv. Ctr., 62 S.W.3d 890 (Tex. App. 2001). “006 of the Texas Education Code, which grants employees and volunteers of a regional education service center the same immunity from liability as school district employees and volunteers.”
Myers v. Doe, 52 S.W.3d 391 (Tex. App. 2001). “Tex.Educ. Code Ann. § 22.051(a) (Vernon 1996).”
Morris v. Dearborne, 181 F.3d 657 (5th Cir. 1999). “Tex. Educ.Code § 22.051(a). The parties do not dispute that Dearborne was an employee of the school district or that she was acting within the scope of her duties.”
Morrone v. Prestonwood Christian Academy, 215 S.W.3d 575 (Tex. App. 2007).
— Tex. Educ. Code § 22.051(a)(1) — 2 cases
Choctaw Props., L.L.C. v. Aledo I.S.D., 127 S.W.3d 235 (Tex. App. 2003). “Laws 2207 , 2283 (amended 2003) (current version at Tex. Educ.Code Ann. § 22.051(a)(1) (Vernon Supp.”
Gonzalez v. Grimm, 353 S.W.3d 270 (Tex. App. 2011).
— Tex. Educ. Code § 22.051(a)(5) — 2 cases
Gil Ramirez Grp., L.L.C. v. Houston Indep. Sch. Dist., 786 F.3d 400 (5th Cir. 2015). “Provisions of the Texas Education Code define a school board trustee as an employee, Tex. Educ. Code § 22.051, 19 and grant immunity to “employees” for “any act that is incident to or within the scope of the duties of the employee’s position .”
La Joya Indep. Sch. Dist. v. Ruth Villarreal, Individually & Ruth Villarreal Ins. Llc (Tex. App. 2014).
— Tex. Educ. Code § 22.051(b) — 1 case
Gonzalez v. Grimm, 353 S.W.3d 270 (Tex. App. 2011).
— Tex. Educ. Code § 22.051(c) — 1 case
Davis v. Educ. Serv. Ctr., 62 S.W.3d 890 (Tex. App. 2001). “006 of the Texas Education Code, which grants employees and volunteers of a regional education service center the same immunity from liability as school district employees and volunteers.”
— Tex. Educ. Code § 22.051(c)(1) — 2 cases
Kobza v. Kutac, 109 S.W.3d 89 (Tex. App. 2003). “See Tex. Educ.Code Ann. § 22.051 (West 1996).”
Carey v. Aldine Indep. Sch. Dist., 996 F. Supp. 641 (S.D. Tex. 1998).
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