Tarrant County, Texas v. Roderick Lydell Bonner, 574 S.W.3d 893

While working, a jail officer (Barham) damaged a chair; he reported it, filled out a report, and placed the chair in a locked multipurpose room used occasionally for inmate medical treatment.
Four days later inmate Roderick Bonner sat in the damaged chair during a diabetes treatment; the chair collapsed and Bonner was injured.
Bonner sued Tarrant County under the Texas Tort Claims Act alleging negligence: failure to remove the chair, failure to warn, and allowing/use of the broken chair during medical treatment.
County asserted statutory immunity from liability under Tex. Code Crim. Proc. art. 42.20 and Tex. Gov’t Code § 497.096, which apply to acts or omissions "in connection with" inmate activities and shield defendants unless conduct was committed with "conscious indifference" or similar heightened culpability.
Trial court granted summary judgment for the County, finding the statutes applied and Bonner failed to raise a fact issue of conscious indifference; the court of appeals reversed as to some claims, concluding certain omissions were not "in connection with" the treatment.
The Supreme Court of Texas reversed the court of appeals, holding the statutes cover the alleged omissions and that Bonner produced no evidence of conscious indifference or extreme risk sufficient to defeat immunity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether article 42.20 and §497.096 apply to County acts/omissions relating to the broken chair	Bonner: omissions (storage/failure to warn) were not "in connection with" his medical treatment, so statutes don't apply	County: "in connection with" requires only a reasonable/causal relation; the chair’s condition intersected with the treatment, so statutes apply	Statutes apply: acts/omissions reasonably related (including indirect/tangential) to covered inmate treatment activities
Whether evidence raises fact issue of "conscious indifference" (heightened standard)	Bonner: conscious indifference is a lesser standard than gross negligence; evidence of knowledge and risk of harm suffices	County: plaintiff must prove subjective awareness of an extreme risk and probable harm; record lacks such evidence	No genuine issue: evidence did not show extreme risk plus subjective awareness; summary judgment for County affirmed

ExxonMobil Pipeline Co. v. Coleman, 512 S.W.3d 895 (Tex. 2017) (construing "in connection with" as involving or concerned, allowing tangential relationships)
DeWitt v. Harris County, 904 S.W.2d 650 (Tex. 1995) (governmental liability under Tort Claims Act depends on employee liability)
State v. Shumake, 199 S.W.3d 279 (Tex. 2006) (gross negligence involves subjective awareness of extreme risk indicating conscious indifference)
Transp. Ins. Co. v. Moriel, 879 S.W.2d 10 (Tex. 1994) (discussion of conscious indifference as requiring proof of actual subjective knowledge of extreme risk)
Tarrant County v. Morales, 207 S.W.3d 870 (Tex. App.—Fort Worth 2006) (applying art. 42.20 and treating conscious indifference as a gross-negligence inquiry)
Lippincott v. Whisenhunt, 462 S.W.3d 507 (Tex. 2015) (treating "in connection with" and "relates to" similarly in statutory construction)