HOUSTON – The Texas 14th Court of Appeals has upheld a lower court’s ruling upholding the Texas Workforce Commission’s denial of unemployment benefits.
The 10th District Court in Galveston County dismissed a lawsuit filed by Keith M. Hill on jurisdictional grounds. The appellate court upheld this decision, stating that Hill's petition was not timely filed.
Hill, a former Clear Creek Independent School District (CCISD) employee, challenged the Texas Workforce Commission’s (TWC) denial of unemployment benefits. In his appeal, Hill alleged that the trial court erred in granting the plea to the jurisdiction filed by the TWC and CCISD.
Hill maintained that the TWC delayed its mailing of a final decision that denied his benefits, which would extend the window for him to seek a review, meaning his petition was filed on time.
Further, Hill also argued that the filing date of his petition “is subject to equitable tolling” because of the “inconsistent” positions taken by TWC, the court's opinion states.
Hill had filed for unemployment benefits after he resigned from the CCISD, and the TWC ultimately determined he was not eligible for benefits.
TWC mailed its final decision to Hill on March 7, 2016, and it stamped the front of the decision with the mailing date and "included a document detailing the relevant deadlines applicable to judicial review, should Hill desire to challenge the decision," the ruling states.
Hill received the final decision on March 11, 2016. He filed a suit seeking judicial review on April 8, 2016.
The TWC argued that Hill failed to file his petition by an April 4, 2016, deadline.
The trial court granted the TWC's plea and dismissed Hill’s case for want of jurisdiction. He then appealed the case.
The panel included Chief Justice Kem Thompson Frost and justices William J. Boyce and Kevin Jewell, who wrote the opinion of the court. Jewell wrote in the Jan. 4 opinion and stated that even assuming the TWC didn’t mail its decision to Hill until March 10, he still filed his suit a day after the deadline.
“Because Hill’s untimely petition failed to confer subject matter jurisdiction on the trial court, the trial court properly granted TWC’s plea to the jurisdiction,” he wrote. “We overrule Hill’s first issue.”
In his second issue, the court noted that Hill relied on the equitable doctrine of quasi-estoppel to toll the filing date and confer subject matter jurisdiction on the trial court.
Citing Wilmer-Hutchins Independent School District v. Sullivan, Jewell wrote that “a court cannot acquire subject matter jurisdiction through equitable doctrines such as estoppel or waiver when jurisdiction does not otherwise exist.”
“Hill did not file his petition timely, so the trial court lacked subject matter jurisdiction to review TWC’s decision,” Jewell concluded in the court’s opinion. “We overrule Hill’s two issues and affirm the trial court’s order dismissing Hill’s suit.”