Texas Southern University, Texas Southern University President Lesia Crumpton-Young and General Counsel Hao Le v. Mary Young

Summary

The Texas Supreme Court denied review and mandamus, holding that a trial court did not abuse its discretion by ordering targeted jurisdictional discovery before ruling on a sovereign-immunity-based plea to the jurisdiction. The case involves an ultra vires claim under Texas Government Code § 614 (law enforcement officer complaint procedures), where factual disputes about whether disciplinary action was taken before providing a signed complaint are jurisdictional, not merely merits-based. While courts must resolve jurisdiction before reaching the merits, they may authorize discovery necessary to determine jurisdictional facts, even if it overlaps with merits issues.

Holdings

1. The trial court did not improperly order merits discovery; the discovery ordered was permissible jurisdictional discovery necessary to resolve factual issues related to the plea to the jurisdiction.

Questions Presented

1. Whether the trial court improperly ordered merits discovery before ruling on TSU's sovereign-immunity-based plea to the jurisdiction.

Disposition

writ_denied