Texas Department of Transportation v. James Ricky Tarver
The Texas Department of Transportation (TxDOT) appealed the denial of its plea to the jurisdiction and motions for summary judgment in a case brought by James "Ricky" Tarver. Tarver alleged TxDOT negligently failed to maintain a streetlight, causing his vehicle to collide with a dirt embankment and resulting in injuries. TxDOT argued that Tarver failed to provide timely pre-suit notice as required by the Texas Tort Claims Act (TTCA) and that TxDOT lacked actual notice of the claim. Tarver countered that a DPS officer's crash report, which noted a burned-out streetlight, constituted actual notice to TxDOT. However, the appellate court ruled that notice to one governmental unit, such as the Texas Department of Public Safety (DPS), cannot be imputed as actual notice to another separate governmental unit, like TxDOT, under the TTCA unless an agency relationship with a duty to report alleged fault is established. Consequently, the court found that Tarver failed to satisfy the jurisdictional notice requirements for waiving sovereign immunity. The trial court's judgment was reversed, and Tarver's claim against TxDOT was dismissed for lack of jurisdiction.