City of Houston v. Christopher Rhule, 417 S.W.3d 440

This is a Texas Supreme Court workers’ compensation case about whether a claimant must exhaust administrative remedies before suing for breach of a settlement.
Rhule, a Houston firefighter, sustained an on-the-job injury in 1988; settlement provided $14,000 and lifetime medical expenses, releasing the City from further claims.
The City stopped paying for Rhule’s medical care in 2004; Rhule sued in 2008 for breach of the settlement agreement.
A jury awarded Rhule damages; the court of appeals initially reversed, then affirmed after rehearing and dismissal for lack of jurisdiction.
The dispositive issue is whether section 12b of former Article 8307 required exhaustion of administrative remedies before district-court litigation, given the injury date and the preexisting settlement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rhule was required to exhaust administrative remedies before suit.	Rhule exhausted by securing the original settlement.	Section 12b required Division exhaustion; otherwise jurisdiction lacking.	Yes; exhaustion required, jurisdiction lacked.

Subaru of Am., Inc. v. David McDavid Nissan, Inc., 84 S.W.3d 212 (Tex. 2002) (exclusive agency jurisdiction governs exhaustion requirement)
Cash Am. Int’l., Inc. v. Bennett, 35 S.W.3d 12 (Tex. 2000) (exhaustion as a timing mechanism for admin review)
Cypress-Fairbanks I.S.D. v. Cypress-Fairbanks I.S.D., 830 S.W.2d 88 (Tex. 1992) (exhaustion required absent good cause or waiver)
In re United Servs. Auto. Ass’n, 307 S.W.3d 299 (Tex. 2010) (subject-matter jurisdiction review may occur on appeal)
Univ. of Tex. Sw. Med. Ctr. v. Loutzenhiser, 140 S.W.3d 351 (Tex. 2004) (jurisdictional review; scope of agency authority)
Dubai Petroleum Co. v. Kazi, 12 S.W.3d 71 (Tex. 2000) (statutory jurisdiction principles apply to exhaustion)