In Re United Services Automobile Ass'n
2010 Tex. LEXIS 282, 53 Tex. Sup. Ct. J. 485, 307 S.W.3d 299 (2010)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A plaintiff's strategic decision to file a lawsuit in a court with knowledge that their claimed damages exceed the court's jurisdictional limit constitutes "intentional disregard of proper jurisdiction" under Texas's tolling statute, Tex. Civ. Prac. & Rem. Code § 16.064, thus forfeiting the statute's protection against a statute of limitations defense. The two-year statute of limitations under the Texas Commission on Human Rights Act (TCHRA) is a mandatory requirement, but it is not jurisdictional.
Facts:
- James Steven Brite was employed by USAA.
- USAA terminated Brite's employment when his annual salary was almost $74,000.
- Brite believed his termination constituted illegal age discrimination under the Texas Commission on Human Rights Act (TCHRA).
- Brite sought damages for past lost wages (back pay), future lost wages (front pay), punitive damages, and attorney's fees.
- Brite calculated that his future lost wages alone would total approximately $1,000,000.
Procedural Posture:
- Brite initially sued USAA in the Bexar County Court at Law No. 7, a court with a $100,000 jurisdictional limit.
- The trial court denied USAA's plea to the jurisdiction, which argued Brite's damages exceeded the court's limit.
- Following a jury trial, the court entered a judgment for Brite for over $967,000.
- An intermediate court of appeals affirmed the trial court's judgment.
- In a prior proceeding (Brite I), the Supreme Court of Texas reversed and dismissed the suit for want of jurisdiction.
- Within 60 days of the dismissal, Brite refiled his lawsuit against USAA in a Bexar County district court, a court of proper jurisdiction.
- USAA filed a motion for summary judgment, arguing the claim was barred by the statute of limitations because the tolling statute did not apply.
- The district court denied USAA's motion.
- An intermediate court of appeals denied USAA's petition for mandamus relief.
- USAA then petitioned the Supreme Court of Texas for a writ of mandamus to compel the district court to grant its summary judgment motion.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a plaintiff's strategic decision to file a lawsuit in a court with knowledge that their claimed damages exceed the court's monetary jurisdictional limit constitute 'intentional disregard of proper jurisdiction' under Tex. Civ. Prac. & Rem. Code § 16.064, thereby precluding the tolling of the statute of limitations?
Opinions:
Majority - Chief Justice Jefferson
Yes, a plaintiff's strategic decision to file in a court knowing their damages exceed that court's jurisdictional limit constitutes 'intentional disregard of proper jurisdiction,' precluding the application of the tolling statute. First, the court clarified that the TCHRA's two-year statute of limitations is mandatory but not jurisdictional, overruling prior precedent and aligning Texas law with federal interpretations of Title VII. This determination allows for the potential application of the tolling statute, § 16.064, to TCHRA claims. However, the court found that Brite did not qualify for the statute's protection because his filing was not a good-faith mistake. The purpose of § 16.064 is to protect litigants who mistakenly file in the wrong court due to Texas's complex jurisdictional rules, not to remedy tactical decisions. Brite unquestionably sought damages far exceeding the $100,000 limit of the county court at law, as evidenced by his salary, his claims for future wages, and his failure to plead that his damages were within the jurisdictional limits. Because this was a strategic choice rather than an error, it constituted 'intentional disregard,' meaning the statute of limitations was not tolled and his subsequent lawsuit was time-barred.
Analysis:
This decision significantly clarifies the 'intentional disregard' exception to Texas's statutory tolling provision, establishing a clear distinction between good-faith jurisdictional mistakes and deliberate forum-shopping. By holding that a knowing decision to file in a court lacking jurisdiction is a tactical choice not protected by the statute, the Court disincentivizes plaintiffs from filing claims in courts with known jurisdictional defects to gain a procedural advantage. Furthermore, the Court's holding that the TCHRA's time limit is not jurisdictional modernizes state law, aligning it with federal Title VII jurisprudence and the Court's own post-Dubai trend of narrowly construing jurisdictional requirements to promote the finality of judgments.
