Phil Wilson, in His Official Capacity as General Manager of the Lower Colorado River Authority And Timothy Timmerman Thomas Michael Martine J. Scott Arbuckle Steve K. Balas Lori A. Berger Joseph M. Crane Pamela Jo Ellison John M. Franklin v. New Braunfels Utilities, 536 S.W.3d 5

New Braunfels Utilities (NBU) sued the Lower Colorado River Authority (LCRA) officials seeking quiet title, declaratory relief, and attorney’s fees regarding water rights originally under Certified Filing No. 135.
NBU alleged LCRA executed an absolute quitclaim in 1978 transferring all its rights to NBU, and that subsequent adjudication and a Certificate of Adjudication confirmed NBU’s title; NBU attached the quitclaim, a Victoria County final judgment, and the certificate to its petition.
Leases executed in 1978 and 1987 contained language purporting to reserve a reverter right to LCRA; decades later LCRA asserted it retained a reverter interest and notified NBU in 2014.
NBU moved for summary judgment to quiet title; LCRA Officials filed a plea to the jurisdiction asserting governmental (sovereign) immunity and argued NBU’s claims were essentially contractual and sought to extinguish LCRA’s contract right.
The trial court denied the plea to the jurisdiction as to the LCRA Officials and granted NBU’s summary judgment; the Officials appealed the interlocutory denial of their plea.

Issue	Plaintiff's Argument (NBU)	Defendant's Argument (LCRA Officials)	Held
Whether NBU’s pleadings overcome governmental immunity	NBU alleged title-based, ultra vires claims: quiet title and declaratory relief showing LCRA officials claim a cloud on NBU’s title	Officials argued immunity bars suit because the dispute is contract-based (reversionary right) and not a true title/possession dispute	Court held pleadings allege title-based claims that fall within the Lain/Sawyer Trust exception to immunity; plea denied
Whether the Lain/Sawyer Trust exception extends to alleged reverter (future) interests	NBU: reverter claim is a property interest and officials’ assertion constitutes a present claim/possession affecting title	Officials: reverter is non-possessory and not subject to trespass-to-try-title or the title-based exception; allowing suit would improperly expand the exception	Court held reversionary interests can be viewed as present property interests for purposes of Lain/Sawyer Trust; exception applies and jurisdiction is shown

Texas Dep’t of Parks & Wildlife v. Miranda, 133 S.W.3d 217 (Tex. 2004) (standard for pleading-stage jurisdictional review and governmental-immunity pleas)
State v. Lain, 349 S.W.2d 579 (Tex. 1961) (procedure permitting suits against state officials to resolve title/possession disputes despite sovereign immunity)
Texas Parks & Wildlife Dep’t v. Sawyer Trust, 354 S.W.3d 384 (Tex. 2011) (reaffirming Lain and permitting ultra vires/title claims against officials to resolve streambed ownership)
Texas Natural Res. Conservation Comm’n v. IT-Davy, 74 S.W.3d 849 (Tex. 2002) (limits on circumventing sovereign immunity via procedural labels)