Wichita Falls State Hospital v. Taylor

Summary

The Supreme Court of Texas held that Texas Health and Safety Code section 321.003, concerning violations of the patient's bill of rights, did not clearly and unambiguously waive the State's sovereign immunity from suit. The court reversed the court of appeals and dismissed the plaintiff's wrongful-death and survival claims against Wichita Falls State Hospital for want of jurisdiction.

Holdings

1. Section 321.003 does not clearly and unambiguously waive the State's sovereign immunity from suit. The phrase permitting a harmed person to sue a mental health facility, together with the incorporated definition that includes state-operated facilities, is insufficient to establish an unmistakable legislative consent to suit against the State.
2. Because the State retained sovereign immunity from suit, the Hospital's jurisdictional challenge must be sustained and Taylor's claims dismissed for want of jurisdiction.

Questions Presented

1. Whether Texas Health and Safety Code section 321.003 clearly and unambiguously waives the State's sovereign immunity from suit for violations of the patient's bill of rights.
2. Whether the incorporation of the definition of "mental health facility" from section 571.003 into chapter 321 constitutes a waiver of sovereign immunity for claims against state-operated mental health facilities.
3. Whether the Hospital's plea to the jurisdiction should be granted and Taylor's claims dismissed for want of jurisdiction.

Disposition

reversed_and_remanded