Texas Department of Human Services v. Okoli
Oliver E. Okoli (appellee), a former caseworker for the Texas Department of Human Services (TDHS) (appellant), sued TDHS under the Texas Whistleblower Act after being terminated. Okoli alleged his supervisor engaged in fraudulent conduct by falsifying dates on benefit applications and reported this up his chain of command. TDHS filed a plea to the jurisdiction, arguing Okoli's supervisors were not appropriate law enforcement authorities for such reports and that his fraud and malice claims were barred by sovereign immunity. This Court affirmed the trial court's denial of TDHS's plea, holding that TDHS's own policies requiring employees to report unlawful conduct up the chain of command meant the supervisors could be considered appropriate authorities or that Okoli had a good faith belief they were. The Court also reiterated that fraud and malice are allegations for damages, not separate causes of action implicating jurisdiction.