Carrizales v. Texas Department of Protective & Regulatory Services
Armando Carrizales appealed an administrative law judge's (ALJ) decision, which affirmed the Texas Department of Protective and Regulatory Services' finding of child neglect against him. This finding led to Carrizales's name being placed in a central registry, effectively prohibiting his future employment with children. Carrizales initially sought judicial review in the district court, citing the Administrative Procedure Act (APA) as the basis for his appeal, but the district court dismissed the petition for lack of subject-matter jurisdiction. On appeal, Carrizales introduced an argument for an inherent right to judicial review, claiming his constitutional liberty interest in employment was violated. However, the appellate court ruled that this constitutional argument was not preserved in the district court and therefore could not be considered on appeal. Consequently, the appellate court affirmed the district court's dismissal of Carrizales's petition.