Supreme Court
City of Houston v. Rodriguez
- Case number: 23-0094
- Legal category: Governmental Immunity
- Subtype: Official Immunity
- Set for oral argument: September 10, 2024
Case Summary
At issue in this case is whether a police officer acted with reckless disregard such that the Texas Tort Claims Act’s emergency exception does not apply, and whether the officer acted in good faith such that he is entitled to official immunity.
Officer Corral was engaged in a high-speed chase with a suspect who drove erratically, at high speeds, and at one point against traffic. Corral tried to make a sudden right turn but was unable to complete it because of the speed at which he was traveling. He swerved into the curb to avoid hitting a truck waiting at the stop sign but lost control and struck the truck. Corral produced affidavit testimony asserting that he only hit the curb because his brakes were not working.
The City filed a motion for summary judgment asserting official immunity and immunity under the Texas Tort Claims Act’s emergency exception. The trial court denied the motion, and the court of appeals affirmed. The court held that the City did not meet its initial burden to demonstrate good faith because Corral’s affidavit did not assess the risk of harm in light of the condition of his vehicle’s brakes and that Corral’s alleged brake failure raises a fact issue as to whether he acted recklessly.
The City filed a petition for review, arguing that Corral engaged in risk assessment measures that precluded a fact issue for recklessness and that the unrefuted evidence offered by both parties establishes Corral’s good faith. The City also argues that nothing in the record provides a reasonable inference that Corral’s brakes were malfunctioning or that he was aware his brakes were malfunctioning before the incident. The Supreme Court granted the petition.
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