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In Re Metropolitan Transit Authority
334 S.W.3d 806
Tex. App.
2011
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Background

  • Metro sought a writ of mandamus to compel a trial court to set aside its denial of Metro's plea to the jurisdiction based on failure to exhaust administrative remedies.
  • The underlying workers' compensation claim involved Sharon Wilson, a Metro bus driver, alleging a compensable injury plus a foot injury with infection and toe amputation.
  • The administrative process included a benefit review conference, potential arbitration, a contested case hearing, and an administrative appeals panel that reversed the hearing officer in Wilson's favor on compensability and extent of injury.
  • Metro challenged the appeals panel's decision, arguing the district court is limited to review of the waiver issue and that Wilson had not exhausted administrative remedies on other issues.
  • Wilson defended that she appealed all hearing officer findings to the appeals panel and that the appeals panel decided issues of compensability and extent of injury in her favor, permitting defense in district court.
  • The district court denied Metro's plea to the jurisdiction; Metro filed a petition for mandamus.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Whether the district court has jurisdiction to review the extent of Wilson's injury. Wilson exhausted administrative remedies by appealing to the appeals panel. Metro argues only waiver/administrative-remedies exhaustion should be reviewed. District court has jurisdiction; not limited to waiver issue.

Key Cases Cited

  • In re Laibe Corp., 307 S.W.3d 314 (Tex.2010) (mandamus relief standards for agency exhaustion)
  • In re Columbia Med. Ctr. of Las Colinas, 306 S.W.3d 246 (Tex.2010) (orig.proceeding; per curiam; review of agency action)
  • In re Cerberus Capital Mgmt., L.P., 164 S.W.3d 379 (Tex.2005) (orig.proceeding; per curiam; standards for mandamus review)
Read the full case

Case Details

Case Name: In Re Metropolitan Transit Authority
Court Name: Court of Appeals of Texas
Date Published: Feb 28, 2011
Citation: 334 S.W.3d 806
Docket Number: 01-10-00752-CV
Court Abbreviation: Tex. App.