Texas Appellate Court Lacked Jurisdiction Over Private Company’s Appeal of Denial of Summary Judgment Based on Immunity – Aecom USA, Inc. v. Mata

Supreme Court

In order for a trial court to adjudicate a case, it must have jurisdiction (both personal jurisdiction and subject matter jurisdiction) over the matter at hand. The same is true for an appellate court. It also must have jurisdiction over an appeal before it may proceed.

The mere fact that a lawsuit has been filed in a trial court (or an appeal taken to the court of appeals) is not enough. The court must have the legal authority to act, or else its decision will be invalid. Recently, a Texas appellate court was called upon to determine an interlocutory appeal in a case in which a private company that had contracted with the Texas Department of Transportation sought interlocutory review of a trial court’s denial of its motion for summary judgment based on immunity. First, the court had to determine whether it had jurisdiction over the appeal.

Facts of the Case

In the case of Aecom USA, Inc. v. Mata, the plaintiffs were members of a family that was involved in a traffic accident that occurred when their car left the roadway and struck a steel pole located on a concrete traffic island. One member of the family died in the accident. The family members filed suit against the defendant, a private engineering company, alleging that it was negligent in designing the intersection where the wreck happened. The defendant filed a motion for summary judgment, arguing that it was immune from suit based on sovereign immunity or official immunity.

The trial court granted the defendant’s motion but later changed its decision to deny summary judgment to the defendant. The defendant sought review of the trial court’s interlocutory motion denying its motion for summary judgment based on sovereign immunity.

Decision of the Court of Appeals

The appellate court dismissed the appeal, holding that it lacked jurisdiction to consider the merits of the interlocutory appeal. Although the defendant argued that the court had jurisdiction pursuant to § 51.014(a)(8) of the Texas Civil Practice and Remedies Code, the court disagreed. Generally, only final orders and judgments are appealable, but § 51.014(a)(8) authorizes an immediate appeal from an interlocutory order that “grants or denies a plea to the jurisdiction by a governmental unit as that term is defined in § 101.001 [of the Texas Civil Practice and Remedies Code.]”

Since the defendant did not qualify as a “governmental unit” under § 101.001(3), its interlocutory appeal did not qualify for the narrow exception to the general rule that only final judgment and orders can be appealed.

An Experienced East Texas Car Accident Attorney on Your Side

If you have been involved in a car wreck and need to talk to an experienced east Texas car accident lawyer about your right to pursue a negligence claim against the responsible party, the law offices of Earl Drott, P.C. is here to help. For an appointment to discuss how we can put our 30 years of experience to work on your Tyler or Smith County personal injury or wrongful death case, call (903) 531-9300.

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Texas Appeals Court Holds that Separate Governmental Tort Liability Limits Applied to Multiple Defendants – Rodriguez v. Fort Worth Transportation Authority