Wichita County v. Hart
Texas Supreme Court
917 S.W.2d 779 (1996)
- Written by Kelsey Libby, JD
Facts
Allen Hart and Ernie Williams (the deputies) (plaintiffs) were employed as deputies in the Wichita County Sheriff’s Department (the county) (defendant). In February 1989, the deputies reported to law enforcement that they believed the sheriff had done something illegal. An investigator from the district attorney’s office spoke to the sheriff, and the sheriff terminated Hart the same day and Williams two days later. The deputies sued the county under the Texas Whistleblower Act, which protected employees who reported a violation of law in good faith. At trial, the jury was instructed that the term good faith meant honesty in fact and that a report could be in good faith even if incorrect, as long as the belief was not unreasonable. The jury returned a verdict in favor of the deputies, and the court of appeals affirmed. The county appealed to the Texas Supreme Court, arguing that the jury should have been instructed that good faith meant without impure motivations such as malice, spite, jealousy, or personal gain. The supreme court determined as an initial matter that the trial court erred in not transferring venue and reversed the verdict on that basis. Because the matter was to be remanded, the court also considered the proper definition of good faith to be applied.
Rule of Law
Issue
Holding and Reasoning (Spector, J.)
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