City of North Richland Hills, Texas v. Laura Friend, 370 S.W.3d 369

Sarah Friend collapsed July 14, 2004 at NRH Oasis water park owned by City of North Richland Hills.
City employees used airway equipment but did not retrieve an AED from a distant storage area.
Defibrillation was delayed 21 minutes after collapse; Sarah died shortly after noon.
Estate sued City and employees for gross negligence in failing to use or obtain the AED.
The trial court dismissed the employees under 101.106(e); City sought additional dismissal under 101.106(b) and immunity defenses.
Court of Appeals majority found waiver under 101.021(2) and rejected sufficiency of conscious indifference; Texas Supreme Court reversed on immunity issue.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether 101.021(2) waives immunity for this claim.	Friend alleges property lacks integral safety component.	City argues no waiver because not use/condition of property per 101.021(2).	Immunity not waived under 101.021(2); dismissal proper.

Lowe v. Texas Tech Univ., 540 S.W.2d 297 (Tex. 1976) (integral safety component doctrine limited to lacking component)
Robinson v. Cent. Tex. MHMR Ctr., 780 S.W.2d 169 (Tex. 1989) (waiver when property provided lacks integral safety component)
Kerrville State Hosp. v. Clark, 923 S.W.2d 582 (Tex. 1996) (limits on integral safety component doctrine)
Tex. A&M Univ. v. Bishop, 156 S.W.3d 580 (Tex. 2005) (limits to when lack of safety component suffices)
Kassen v. Hatley, 887 S.W.2d 4 (Tex. 1994) (mere nonuse not enough to waive immunity)