Deputy Corey Alexander and Sergeant Jimmie Cook v. April Walker

In Texas Adjutant General’s Office v. Ngakoue (TAGO), 408 S.W.3d 350 (Tex.2013), we considered the election-of-remedies provision of the Texas Tort Claims Act (TTCA). See Tex. Civ. Prac. & Rem. Code § 101.106. In that opinion, we clarified that one of the provision’s purposes is to encourage plaintiffs “to pursue lawsuits against governmental units rather than their employees when the suit is based on the employee’s conduct within the scope of employment.” TAGO, 408 S.W.3d at 352. We realized that purpose by holding that a common-law tort suit against a government employee for conduct within…