Rogelio Regalado v. Management & Training Corporation and Warden L. Thomas, 02-23-00351-CV

Rogelio Regalado, an inmate in TDCJ custody, sued Management & Training Corporation (MTC) and Warden L. Thomas for failing to provide Kosher meals at the Bridgeport correctional facility.
He asserted violations of his religious rights under the Texas Constitution, seeking damages and injunctive and declaratory relief.
Regalado followed the prison grievance procedure before filing suit, but was transferred to a different unit prior to filing.
The trial court dismissed his case under Chapter 14 of the Texas Civil Practice and Remedies Code, which governs inmate litigation.
Regalado appealed, arguing compliance with procedures and asserting claims under federal law and that MTC could not claim sovereign immunity as a private contractor.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sovereign Immunity	MTC, as a private corporation, is not immune from suit.	MTC is entitled to sovereign immunity as a state contractor.	MTC cannot claim sovereign immunity for these alleged acts.
Damages for Texas Constitution Violation	Entitled to damages for violation of religious rights.	No private right of action for damages exists under TX Constitution.	No damages available for alleged constitutional violation.
Injunctive/Declaratory Relief	Entitled to relief compelling provision of Kosher meals.	Claims are moot since plaintiff is no longer at MTC facility.	Claims for injunctive/declaratory relief are moot.
Negligence Claims	Defendant failed to provide a nutritious, religiously appropriate diet.	Claims inadequately pled; no legal/factual basis shown.	Negligence claims waived for inadequate briefing.

City of Beaumont v. Bouillion, 896 S.W.2d 143 (Tex. 1995) (no private damages action for violation of the Texas Constitution)
Republican Party of Tex. v. Dietz, 940 S.W.2d 86 (Tex. 1997) (Bill of Rights generally applies to government actions)
Rusk State Hosp. v. Black, 392 S.W.3d 88 (Tex. 2012) (immunity as a jurisdictional question)
University of the Incarnate Word v. Redus, 602 S.W.3d 398 (Tex. 2020) (private contractor immunity depends on government control)
City of Arlington v. Randall, 301 S.W.3d 896 (Tex. App.—Fort Worth 2009) (no damages for constitutional violations)