VanDevender v. Woods

Deputy Sheriff James VanDevender sought a declaratory judgment that Jefferson County and its sheriff, G. Mitch Woods, violated article III, section 52e of the Texas Constitution 1 by failing to pay VanDevender’s full salary during his second term as a deputy sheriff after he became disabled. That constitutional provision grants county law enforcement officers their “maximum salary” while they are “hospitalized or incapacitated” until their “term of office” expires. The trial court and court of appeals held that the Constitution did not entitle VanDevender to salary continuation benefits. We…