Texas Department of Criminal Justice v. Simons
The Texas Department of Criminal Justice-Institutional Division (TDCJ) appealed the trial court's denial of its plea to the jurisdiction and no-evidence motion for summary judgment. The case involves Brian Edward Simons, an incarcerated individual who sued TDCJ for injuries. The central legal question is whether TDCJ received "actual notice" of Simons's claim, a requirement under the Texas Tort Claims Act. The court considered the recent amendment to Government Code section 311.034, which makes statutory prerequisites to suit jurisdictional, and applied it retroactively. Analyzing the "subjective awareness" standard for actual notice, the court found that TDCJ's internal investigation, which concluded Simons was at fault, and communications from Simons's legal assistant, did not demonstrate TDCJ had subjective awareness that its own fault contributed to Simons's injury. Consequently, the court held that TDCJ lacked actual notice, reversed the trial court's order, and dismissed Simons's claim for want of jurisdiction.