Grounds v. Tolar Indep. Sch. Dist

In Grounds v. Tolar Indep. Sch. Dist., 707 S.W.2d 889, 892, 29 Tex. Sup. Ct. J. 307 (Tex. 1986), a teacher/head football coach was informed by the Tolar Independent School District that his contract would not be renewed. Id. at 890. Grounds appealed the school district's decision, which resulted in the State Commissioner of Education ordering Grounds's re-employment in the "same professional capacity." Id. The school district neither filed a motion for rehearing nor appealed the State Commissioner of Education's decision in a Travis County district court, both actions required by the Administrative Procedure and Texas Register Act. Id. Instead, theschool district attacked the administrative order in district court in Hood County. Id. The district court rendered judgment for the school district and the court of appeals affirmed. Id. The primary issue in Grounds, according to the supreme court, is whether an administrative order is subject to collateral attack in violation of the procedural prerequisites of the agency's enabling statute and the Administrative Procedure and Texas Register Act. Id. The supreme court found that the school district did not follow the mandatory and exclusive statutory prerequisites for review, and did not invoke the jurisdiction of the Hood County district court. Id. at 892.