ROCKWALL, TX — The Fifth District Court of Appeals has reversed a trial court’s decision by dismissing personal injury claims against three former cheerleading coaches of Rockwall-Heath High School (RHHS). This case, stemming from a disciplinary incident in 2024 that resulted in a student being hospitalized, underscores the legal protections provided to government employees under Texas law.
The Incident and Allegations
The lawsuit was initiated by Robert and Misty Hanvey on behalf of their daughter, E.H., a student and cheerleader at RHHS. According to court documents, the situation escalated on October 15, 2024, during a cheerleading class. The Hanveys allege that coaches Amanda Jones, Ryleigh Valladarez, and Kaley Stewart compelled students to perform fifty modified burpees, which included push-ups, as punishment for perceived underperformance of the team.
Sadly, this punishment had dire medical repercussions for E.H., leading to a diagnosis of Exertional Rhabdomyolysis, a serious condition characterized by the breakdown of muscle tissue that releases harmful proteins into the bloodstream. She required overnight treatment in an emergency room with IV fluids.
The Hanveys’ petition included alarming details from a student incident report:
E.H. had a doctor’s note exempting her from physical exercise due to strep throat at the time of the punishment.
Despite her illness, the coaches allegedly insisted she perform the exercises.
E.H. was described as "visibly in distress," yet Coach Jones reportedly shouted at her to complete the task.
Teachers allegedly threatened additional punishments if the exercises were not performed correctly.
District Findings and Resignations
In the aftermath of the incident, a Rockwall ISD investigation determined that the coaches' actions breached at least five district policies, including those related to Student Discipline, the Educator Code of Ethics, and Employee Standards of Conduct. The investigation revealed that:
Evidence indicated that the burpee exercises may have contributed to E.H.'s medical condition.
The exercise was improperly used as punishment for an incorrect routine.
The coaches disregarded the student’s doctor's orders to avoid physical activity.
The coaches lacked sufficient knowledge and training regarding Rhabdomyolysis.
As a result of these findings, all three coaches resigned from their positions with the cheerleading team during or after the investigation.
The Legal Turning Point
While the district investigated the facts surrounding the incident, the legal dispute focused on the question of who could be held liable in a civil court. The coaches sought to dismiss the claims against them personally, citing the Texas Tort Claims Act’s election-of-remedies provision. This law generally dictates that when a government employee is sued for actions within the "general scope of their employment," the lawsuit must be directed at the government entity rather than the individuals involved.
The Hanveys contended that the coaches operated outside their scope of employment due to their implementation of prohibited "aversive techniques" and violation of multiple school policies.
However, the Court of Appeals disagreed with this assertion. Justice Nancy Kennedy stated that even if the conduct was negligent or in violation of district policy, it still occurred within the school environment, during school hours, and pertained to disciplinary actions—which fall within the general scope of a teacher's responsibilities.
The Court’s Conclusion
The court concluded that because the coaches were acting within the broad definition of their job responsibilities at the time of the incident, they are immune from being sued individually under Section 101.106(f) of the Civil Practice and Remedies Code. This ruling reverses the trial court's earlier order and effectively dismissing the claims against Jones, Valladarez, and Stewart.
