Laura Beeman and Janet Lock v. Brad Livingston, in His Official Capacity as Executive Director of the Texas Department of Criminal Justice

Deaf inmates housed in a unit of the Texas Department of Criminal Justice (TDCJ) sued TDCJ’s Executive Director, claiming he acted ultra vires because he violated the Texas Human Resources Code by failing to reasonably accommodate their impairment. The trial court agreed with the plaintiffs and ordered TDCJ to make certain accommodations. The court of appeals determined that the Human Resources Code was not applicable to prisons because they are not “public facilities” to which the code applies and the Director had sovereign immunity, so even if the Executive Director did not comply with the…