Texas Association of School Boards Risk Management Fund // Southwest Texas Junior College v. Southwest Texas Junior College // Cross-Appellee, Texas Association of School Boards Risk Management Fund
This case involves an intergovernmental contract dispute between the Texas Association of School Boards Risk Management Fund (Appellant) and Southwest Texas Junior College (Appellee). The College is seeking replacement cost value benefits under a self-insurance contract for property damage allegedly sustained during an April 2021 hailstorm. The College claims a waiver of the Fund’s governmental immunity under TEX. LOC. GOV’T CODE § 271.152, asserting equitable theories of waiver and unconscionability, and intentional torts of fraud and bad faith to expand coverage beyond the express terms of the agreement. The Fund argued that its governmental immunity had not been waived for these claims and damages, emphasizing that statutory waivers are to be narrowly construed. The trial court partially granted the Fund's jurisdictional plea, dismissing claims for exemplary, consequential, or treble damages, but denied the plea regarding the College's equitable and intentional tort theories, viewing them as defensive in nature. The Fund appeals this partial denial, arguing that the Act's narrow immunity waiver does not extend to these theories which attempt to create coverage where none explicitly exists in the written contract.