Crowley Independent School District v. Carl Stoneham, and Mike Morath, in His Official Capacity as Commissioner of Education of Texas
15-24-00051-CV
Tex. App.Jan 16, 2025Background
- Crowley Independent School District (CISD) sought judicial review in district court after the Texas Commissioner of Education reversed CISD's decision to terminate Carl Stoneham and ordered his reinstatement with back pay.
- Prior to the termination, Stoneham attempted to resign, but CISD rejected his resignation.
- After the Commissioner ruled in Stoneham’s favor, CISD later attempted to “accept” his previously rejected resignation to limit its liability for back pay.
- Stoneham sought a declaratory judgment in district court that the purported acceptance of his resignation was null and void, as CISD had already rejected it.
- The main dispute is whether the court had jurisdiction to hear Stoneham's declaratory judgment claim and whether CISD could claim governmental immunity from that claim after it initiated the lawsuit.
Issues
| Issue | Stoneham's Argument | CISD's Argument | Held |
|---|---|---|---|
| Governmental Immunity | No immunity because CISD initiated suit, making it subject to defensive claims under Reata | Immunity bars Stoneham’s declaratory judgment, as declaratory actions can’t extend trial court jurisdiction | Court agrees with Stoneham—no immunity when entity initiates suit |
| Declaratory Judgment Jurisdiction | The claim is germane and defensive to CISD’s own claims, fits under the transaction/occurrence | Claim is an improper expansion of jurisdiction using declaratory relief | The declaratory judgment is within court’s jurisdiction as a defensive claim |
| Exhaustion of Administrative Remedies | Not required—request presents pure questions of law, and administrative remedies are unavailable | (Not expressly argued in current rehearing) | Court finds exhaustion not required for Stoneham’s claim |
| Attorney Fees | (Withdrawn by Stoneham in light of precedent) | (N/A) | (Not awarded) |
Key Cases Cited
- Reata Constr. Corp. v. City of Dallas, 197 S.W.3d 371 (Tex. 2006) (governmental entities that initiate suit are amenable to defensive claims that are germane to their claims)
- Hughes v. Tom Green Cty., 573 S.W.3d 212 (Tex. 2019) (governmental entities that file suit must participate as ordinary litigants)
- C. Borunda Holdings, Inc. v. Lake Proctor Irrigation Auth., 540 S.W.3d 548 (Tex. 2018) (governmental immunity does not bar germane counterclaims in the same suit)