Ronald Williams v. Metropolitan Transit Authority, 01-15-00299-CV

Ronald Williams was a long-time Metro (Metropolitan Transit Authority) maintenance employee with ~19 years’ experience and no prior discipline until a supervisor named Reginald Ratcliff was hired.
Ratcliff allegedly solicited Williams to assist in criminal activity; Williams refused and thereafter experienced repeated harassment and retaliatory conduct by Ratcliff and another supervisor, Fred Burton.
Williams complained internally (to Jackie Castell and Marilyn Moore) and on August 2014 reported alleged criminal conduct to Metro police officers Andre Hines and Michael Garcia.
Metro subsequently disciplined and then terminated Williams on September 17, 2014; Williams claims the termination was retaliatory in violation of the Texas Whistleblower Act.
Williams sued under the Texas Whistleblower Act alleging he reported violations to an appropriate law‑enforcement authority and that sovereign immunity was waived; Metro moved for a plea to the jurisdiction.
The trial court granted Metro’s plea to the jurisdiction (dismissing Williams’ claims); this document is Williams’s appellate brief seeking reversal and remand.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Williams made a good‑faith report to an appropriate law‑enforcement authority under the Texas Whistleblower Act	Williams argues he reported criminal conduct to Metro Police and reasonably believed Metro Police (a local governmental law‑enforcement agency) could investigate/prosecute, satisfying the Act’s requirement	Metro argued Williams did not report to an appropriate law‑enforcement authority such that the Act’s waiver of immunity does not apply	Trial court granted Metro’s plea to the jurisdiction (dismissal) — appellant seeks appellate reversal
Whether the trial court erred in granting the plea to the jurisdiction	Williams contends the pleadings and evidence, construed liberally, show a viable Whistleblower claim and that the plea improperly dismissed his claims before trial	Metro contends the pleadings fail to establish a report to an appropriate authority, so sovereign immunity bars suit	Trial court dismissed for lack of jurisdiction; appellant argues dismissal was improper under Parks & Wildlife/Miranda pleading standard

Tex. Dep’t of Parks & Wildlife v. Miranda, 133 S.W.3d 217 (2004) (explains plea to the jurisdiction standard; pleadings are liberally construed favoring jurisdiction and plaintiff should be allowed to amend if pleadings are insufficient)
State Dep’t of Highways & Pub. Transp. v. Gonzalez, 82 S.W.3d 322 (2002) (appellate review of jurisdictional rulings is de novo)