Background

• Moreno, TAMUK's assistant vice president and comptroller, sued TAMUK for terminating her in violation of the Texas Whistleblower Act after reporting tuition-waiver concerns to TAMUK president Juarez.
• Moreno claimed she made a good-faith report of a law violation to an internal supervisor (Juarez) rather than to an external law-enforcement authority.
• The trial court granted TAMUK's plea to the jurisdiction; the court of appeals reversed and remanded.
• The Act requires reporting a violation of law to an 'appropriate law enforcement authority' defined by external enforcement or regulatory powers, not merely internal compliance.
• Moreno argued that Juarez had authority to enforce state tuition laws; the evidence showed Juarez oversaw internal compliance, not external enforcement.
• This Court held that an entity empowered only to discipline its own employees and ensure internal compliance does not constitute an 'appropriate law enforcement authority' under the Act, so Moreno's report to Juarez did not qualify.

Issues

Key Cases Cited

• Moreno v. Texas A&M Univ.-Kingsville, 339 S.W.3d 902 (Tex. App. 2010) (internal compliance is not external law-enforcement authority under the Act)