James Richards v. Marsha McLane, in Her Official Capacity as Director of the Texas Civil Commitment Office, 07-20-00306-CV

James Richards filed suit in the 459th District Court (Travis County) against executives and staff of the Texas Civil Commitment Office in their official capacities, challenging his inpatient confinement at the Lamb County Texas Civil Commitment Center as a sexually violent predator.
Richards sought an order voiding the commitment-related orders/actions and sought return to outpatient treatment in Houston; he also alleged defendants failed to help him renew his driver’s license or obtain an ID.
The defendants filed a plea to the court’s jurisdiction; the trial court granted the plea and dismissed Richards’s suit for lack of subject-matter jurisdiction.
On appeal the court reviewed the jurisdictional dismissal de novo, examining Richards’s pleadings and any jurisdictional evidence.
The court concluded Richards’s challenge to his confinement and request for less restrictive placement falls within the exclusive continuing jurisdiction of the original committing court under Tex. Health & Safety Code §841.082, not the 459th District Court.
The court further held Richards’s claim under §841.153 (assistance with license/ID) was unripe because the Office’s duty to act arises only upon the committed person’s release, and Richards was not released nor imminently so.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 459th District Court had subject-matter jurisdiction to modify Richards’s commitment or order less restrictive placement	Richards sought judicial relief in Travis County to void commitment actions and secure outpatient placement	Only the original committing court retains jurisdiction to modify commitment, so the 459th lacks authority	Court held 459th lacked jurisdiction; committing court retains control under §841.082
Whether McLane had a duty to help Richards obtain a driver’s license/ID under §841.153	Richards alleged McLane failed to assist in renewing his license/ID and sought relief	Office’s duty to request issuance of an ID arises only upon release of a committed person; Richards was not released or about to be released	Court held the claim unripe and outside subject-matter jurisdiction because the statutory duty is triggered only on release

Tex. Dep’t of Parks & Wildlife v. Miranda, 133 S.W.3d 217 (Tex. 2004) (scope and standards for jurisdictional inquiry; de novo review)
Sw. Elec. Power Co. v. Lynch, 595 S.W.3d 678 (Tex. 2020) (ripeness requirement for subject-matter jurisdiction; claims based on hypothetical or future events are not ripe)