Texas Department of Public Safety v. William Paul Jenkins, Jr.

Summary

The Texas Department of Public Safety appealed the reversal of an administrative order suspending William Paul Jenkins Jr.'s driver's license. The court held that the district court lacked subject-matter jurisdiction because the appeal was not first filed in the county court as required by Texas Transportation Code section 524.041(b). The court vacated the district court's order and dismissed the cause.

Holdings

1. Texas Transportation Code section 524.041(b) confers exclusive jurisdiction over an appeal from an administrative law judge's final decision on the county court at law in the county where the person was arrested, or, if no county court at law exists, on the county court; a district court may hear the appeal only after a proper transfer under the statute.
2. The court did not need to reach the Department's remaining issue because the lack of subject-matter jurisdiction required vacatur of the district court's order and dismissal of the cause.

Questions Presented

1. Whether the Jones County district court had subject-matter jurisdiction to hear Jenkins's appeal from the administrative law judge's final driver's-license suspension order.
2. Whether the court needed to address the Department's remaining appellate issue after determining that the district court lacked subject-matter jurisdiction.

Disposition

vacated