Burnet County Sheriff's Department and Burnet County, Texas v. Zarina Carlisle
Zarina Carlisle, a senior correctional officer, sued Burnet County Sheriff's Department and Burnet County for wrongful termination under the Texas Whistleblower Act, alleging retaliation for reporting unprofessional conduct by her supervisor, Captain Wendell Gilmore. Carlisle reported Gilmore's cursing and 'bad-mouthing' to Sheriff Joe Pollack, believing it violated county personnel policies and constituted disorderly conduct under the Texas Penal Code. Burnet County filed a plea to the jurisdiction, arguing that Carlisle failed to allege a 'violation of law' sufficient to waive sovereign immunity. The appellate court agreed, finding that internal personnel policies do not constitute a 'law' under the Whistleblower Act unless promulgated pursuant to a statute or ordinance, which was not established. Furthermore, Carlisle's allegations did not meet the elements for disorderly conduct. The court concluded that Carlisle failed to plead a cause of action sufficient to invoke the Act's waiver of sovereign immunity, reversing the district court's denial of Burnet County's plea to the jurisdiction.