Margo Frasier, Travis County Sheriff, in Her Official Capacity And Travis County, Texas v. Elvina Yanes, Janet Cisneros and Patricia Mitchell
Three detention officers in the Travis County Sheriff's office were injured while performing their official duties. They sought a declaratory judgment asserting their entitlement to full salary during recovery under Article III, Section 52e of the Texas Constitution. Sheriff Margo Frasier and Travis County filed a plea to the jurisdiction, arguing the constitutional provision was not self-enacting, did not waive sovereign immunity, and that the officers failed to exhaust administrative remedies. The trial court denied the plea. The appellate court affirmed the district court's judgment, holding that Article III, Section 52e is self-enacting, implicitly waives sovereign immunity, and that exhaustion of administrative remedies was not required for pure questions of law.