James Edland v. Town of Cross Roads, Texas, 02-23-00416-CV

James Edland served as police chief of the Northeast Police Department (NEPD), created by an interlocal agreement between the Town of Cross Roads and the City of Krugerville.
Edland entered into an employment contract to act as NEPD’s chief, signed by himself and the chair of the NEPD Commission, but not by representatives of either town.
The contract specified severance pay in certain circumstances and allowed Edland to choose continued employment with one of the municipalities if NEPD dissolved.
In 2021, NEPD dissolved, and Edland was then hired as police chief of Krugerville, beginning the day after NEPD’s dissolution with no gap in his employment.
Edland sued Cross Roads, claiming entitlement to severance pay based on his NEPD contract, alleging NEPD was not a separate legal entity and that the towns were directly responsible for contractual obligations.
The trial court granted summary judgment for Cross Roads, and Edland appealed.

Issue	Edland's Argument	Cross Roads' Argument	Held
Was Cross Roads a party to or bound by the NEPD contract?	NEPD was a joint venture, so the towns were bound through the Board; contract and interlocal agreement must be read together.	Only NEPD was party; contract not executed by Cross Roads; no evidence Board or its chair had binding authority.	Not a party; no evidence of authority to bind Cross Roads.
Did the contract entitle Edland to severance upon NEPD’s dissolution?	Edland was separated; dissolution triggered severance clause, regardless of immediate rehiring.	Edland suffered no separation—immediately rehired; no contractual basis for severance from Cross Roads.	Not entitled to severance from Cross Roads.
Was there sufficient evidence of contract authorization or intent to bind Cross Roads?	Interlocal agreement allowed Board to contract; actions of Board bound towns.	Board could not bind towns without written resolution; contract language excluded nonparties.	No evidence of written resolution or intent to bind.
Should Cross Roads’ summary judgment be affirmed?	No; issues of fact remain regarding intent, privity, and Board authority.	Yes; failure of evidence on contract/privity defeats claim.	Affirmed; summary judgment for Cross Roads upheld.

Seagull Energy E & P, Inc. v. Eland Energy, Inc., 207 S.W.3d 342 (Tex. 2006) (primary concern in contract interpretation is to ascertain and effectuate the parties’ intent)
Heritage Res., Inc. v. NationsBank, 939 S.W.2d 118 (Tex. 1996) (ambiguity and interpretation of contracts are legal questions for the court)
City of San Benito v. Rio Grande Valley Gas Co., 109 S.W.3d 750 (Tex. 2003) (cities are bound only by properly authorized acts or resolutions)
Universal Health Servs., Inc. v. Renaissance Women’s Grp., P.A., 121 S.W.3d 742 (Tex. 2003) (unambiguous contract interpreted by courts as matter of law)
Fort Worth Indep. Sch. Dist. v. City of Fort Worth, 22 S.W.3d 831 (Tex. 2000) (instruments from the same transaction read together to ascertain intent)
City of Houston v. Williams, 353 S.W.3d 128 (Tex. 2011) (document must evidence parties’ intent to be bound to be a valid contract)