Harrison v. Texas Board of Pardons & Paroles
Mary Ann Harrison sued the Texas Board of Pardons and Paroles for the wrongful death of her daughter, who was murdered by a parolee, Jerry McFadden. Harrison alleged negligence due to the Board employees' misuse or non-use of the Field Services Procedural Manual, specifically their failure to contact McFadden's employer, which could have revealed his parole violations and prevented the murder. The Board was granted summary judgment on the grounds that the manual was not 'tangible personal property' within the meaning of the Texas Tort Claims Act. The appellate court affirmed the summary judgment, reasoning that the information contained in the manual is an intangible concept, and thus the state's sovereign immunity was not waived under the Act. The court concluded that allowing such a claim would effectively eliminate the tangible property requirement of the Act.