Hall v. Texas Commission on Law Enforcement, 685 F. App'x 337

Plaintiff Aric Hall lost Texas peace-officer certification after two years of unemployment under a 2012 TCOLE policy placing inactive licenses when not appointed for more than two years.
Hall alleges he was unable to obtain employment after reporting crimes by police officers and that this retaliation led to his prolonged unemployment and loss of certification.
Hall sued the Texas Commission on Law Enforcement (TCOLE) and individual TCOLE officials under 42 U.S.C. § 1983 claiming violations of the First and Fourteenth Amendments (due process and right to petition) and asserting a property interest in initial certification fees.
TCOLE moved to dismiss for lack of subject-matter jurisdiction based on Eleventh Amendment sovereign immunity; individual defendants moved to dismiss asserting sovereign immunity (official-capacity) and qualified immunity (individual-capacity).
The district court dismissed; on appeal the Fifth Circuit affirmed, holding TCOLE and officials in their official capacities are immune and that the complaint failed to overcome qualified immunity for officials sued individually.

Issue	Plaintiff's Argument	Defendant's Argument	Held
State sovereign immunity for TCOLE	Hall asserted TCOLE waived immunity or Congress abrogated it	TCOLE argued Eleventh Amendment bars suit absent clear waiver or abrogation	Court: Eleventh Amendment bars suit; Hall offered no clear waiver or abrogation
Official-capacity suits / Ex parte Young remedy	Hall argued TCOLE policy denies due process and Ex parte Young permits prospective relief	Defendants argued no ongoing violation shown and sovereign immunity still bars official-capacity claims	Court: No ongoing, colorable constitutional violation alleged; Ex parte Young inapplicable; official-capacity claims barred
Qualified immunity for individual defendants (individual capacity)	Hall claimed First and Fourteenth Amendment violations by officials	Officials argued their actions were objectively reasonable and plaintiff failed to plead violation of clearly established law	Court: Complaint too vague to show violation of clearly established rights; qualified immunity applies
First Amendment petition / Due process / Property interest	Hall claimed retaliation for petitioning and a right to a hearing or property in fees	Defendants said Hall failed to link reporting to employment denials and provided no evidence of deprivation without meaningful process	Court: Hall failed to plead facts establishing retaliation or denial of meaningful process or property right

Edelman v. Jordan, 415 U.S. 651 (1974) (Eleventh Amendment bars suits against unconsenting states in federal court)
Port Auth. Trans-Hudson Corp. v. Feeney, 495 U.S. 299 (1990) (limits on exceptions to sovereign immunity)
Sossamon v. Texas, 563 U.S. 277 (2011) (state waiver of immunity must be unequivocal)
Seminole Tribe of Florida v. Florida, 517 U.S. 44 (1996) (Congress may abrogate immunity only pursuant to valid constitutional power)
Ex parte Young, 209 U.S. 123 (1908) (limited exception allowing prospective injunctive relief against state officers)
Boddie v. Connecticut, 401 U.S. 371 (1971) (due-process requirement is a meaningful opportunity to be heard, not necessarily a full adjudication)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (plausibility standard for pleading)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must raise right to relief above speculative level)