Gtech Corp. v. Steele
The case examines derivative sovereign immunity for government contractors under Texas law. The Steele Plaintiffs sued GTECH Corporation, a contractor for the Texas Lottery Commission (TLC), alleging fraud and other claims related to misleading "Fun 5's" scratch-off tickets. GTECH asserted derivative immunity from TLC. The Court held that GTECH was not immune for fraud claims stemming from its independent discretion in not informing TLC about the misleading instructions after a parameter change. However, GTECH was immune for claims based on actions that merely complied with TLC's directives, where it had no discretion to act otherwise. Consequently, the district court's denial of GTECH's plea to the jurisdiction was affirmed in part and reversed in part.