Tjfa, L.P. v. Texas Commission on Environmental Quality and BFI Waste Systems of North America, Inc.
Justice Diane M. Henson provides a concurring and dissenting opinion regarding the interpretation of a statutory service deadline. She agrees with the majority that the failure to effectuate service within the deadline set forth in subsection 361.321(c) of the health and safety code is not jurisdictional. However, she disagrees with the majority's conclusion that this service deadline is mandatory. Henson argues that the statutory service deadline is directory, meaning that dismissal is not required if the plaintiff demonstrates substantial compliance and the Commission is not prejudiced by the delay. She concludes that TJFA substantially complied with the deadline and that the Commission was not prejudiced, advocating for the reversal of the trial court’s dismissal and a remand for further proceedings.