Linda D. Tanner v. Texas Health and Human Services Commission, Julia Murray, Wendy Proctor, and Juan Rodriguez
15-25-00008-CV
Tex. App.Jun 13, 2025Background
- Linda D. Tanner, proceeding pro se, appealed the denial of her application for Temporary Assistance for Needy Families (TANF) benefits by the Texas Health and Human Services Commission (HHSC).
- Tanner repeatedly applied for TANF since 2021, receiving denials each time; she alleges that the agency did not follow the correct legal criteria for eligibility.
- The trial court dismissed her suit for judicial review due to alleged lack of subject matter jurisdiction, citing untimely filing and lack of statutory standing.
- Tanner claims procedural due process and equal protection violations under the Fourteenth Amendment, raising §1983 claims against HHSC officials in their individual capacities.
- She contends that Texas HHSC failed to comply with both state and federal TANF guidelines, and that denial of her judicial review was based on errors over filing timeliness and sovereign immunity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sovereign Immunity | Sovereign immunity does not shield officials sued personally under §1983 for constitutional violations. | Sovereign immunity bars the suit as it is aimed at a state agency and state officials. | Trial court adopted sovereign immunity bar. |
| Due Process/Equal Protection | Denial of benefits and inadequate hearings violated Tanner's procedural due process and equal protection rights. | No constitutional violations occurred; procedures were properly followed. | Dismissal upheld by trial court. |
| Compliance with State/Federal Law | HHSC did not adhere to required federal/state TANF eligibility standards, creating unlawful denials. | Agency followed applicable laws and set income limits; eligibility was properly determined. | Dismissal upheld by trial court. |
| Timeliness of Administrative Appeal | Tanner claims she timely filed her petition, with any late filing due to administrative error or confusion. | The petition was untimely; thus, court lacked subject matter jurisdiction. | Dismissal for untimely filing affirmed. |
Key Cases Cited
- Will v. Michigan Dept. of State Police, 491 U.S. 58 (1989) (state officials in their official capacity are not persons under §1983)
- Hafer v. Melo, 502 U.S. 21 (1991) (state officials can be liable under §1983 in their individual capacity)
- Blum v. Bacon, 457 U.S. 132 (1982) (federal regulations preempt conflicting state provisions under the Supremacy Clause)
- United States v. Curtiss-Wright Export Corp., 299 U.S. 304 (1936) (addressing federal authority over conflicting state actions)
- McMillen v. Tex. Health & Human Servs. Comm’n, 485 S.W.3d 427 (Tex. 2016) (state officials' duty to ensure program compliance with federal law)