City of Elsa, Texas v. M.A.L.

Summary

The Supreme Court of Texas held that a city charter's “sue and be sued” provision did not waive governmental immunity from suits seeking monetary damages. The Court also held that governmental entities may be sued for injunctive relief to remedy alleged violations of the Texas Constitution. The Court reversed and ordered dismissal of the monetary claims, while affirming remand of the constitutional claims for injunctive relief.

Holdings

1. A sue-and-be-sued provision in a city charter does not, by itself, constitute an unambiguous waiver of governmental immunity from suit for monetary damages.
2. Governmental entities may be sued for injunctive relief to remedy violations of the Texas Constitution.

Questions Presented

1. Whether a city-charter provision stating that the City may sue and be sued waives governmental immunity from suit for monetary damages.
2. Whether governmental entities may be sued directly for injunctive relief to remedy alleged violations of the Texas Constitution.
3. Whether the plaintiffs' constitutional claims for injunctive relief had to be dismissed because they were brought against the City rather than individual officials.

Disposition

reversed_and_remanded