Meyers v. JDC/Firethorne, Ltd.
548 S.W.3d 477
| Tex. | 2018Background
- JDC/Firethorne is a developer that submitted plat applications for Sections 16 and 19 of a subdivision in Fort Bend County; those applications were processed by the county engineering department but were not presented to the commissioners court for approval.
- Fort Bend County's Regulations designate the county engineer as the official to receive, deem complete, and present completed plat applications to the commissioners court; the commissioners court (as a body) must approve plats under Tex. Loc. Gov't Code ch. 232.
- JDC/Firethorne alleges County Engineer Richard Stolleis placed its plats on "hold" to extract a road-construction concession and contends Commissioner Andy Meyers instructed the hold.
- JDC/Firethorne sued seeking mandamus against the county engineer and the commissioners court and sought a permanent injunction against Meyers (official capacity) ordering him to stop directing holds on its plats.
- Meyers filed a plea to the jurisdiction arguing governmental immunity and that, as an individual commissioner, he lacks authority over processing/presenting plats; trial court denied the plea and the court of appeals affirmed; the Supreme Court granted review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether JDC/Firethorne has standing to seek injunctive relief against a single county commissioner | Meyers instructed engineering to delay plats; an injunction preventing him from directing holds would redress the injury | Meyers, as an individual commissioner, has no statutory authority to receive/process/present plats, so injunctive relief against him could not redress the injury | No standing; injunction against Meyers would not redress the harm, claim dismissed with prejudice |
Key Cases Cited
- Tex. Ass'n of Bus. v. Tex. Air Control Bd., 852 S.W.2d 440 (Texas 1993) (standing and subject-matter jurisdiction principles)
- Tex. Dep't of Parks & Wildlife v. Miranda, 133 S.W.3d 217 (Texas 2004) (plea to jurisdiction standards and review)
- Heckman v. Williamson Cty., 369 S.W.3d 137 (Texas 2012) (Texas standing test and redressability requirement)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (U.S. 1992) (federal standing: injury-in-fact, causation, redressability)
- Tex. A&M Univ. Sys. v. Koseoglu, 233 S.W.3d 835 (Texas 2007) (interlocutory appeal under civil practice §51.014 and official-capacity/individual-capacity distinctions)