Houston Fed'n of Teachers v. Houston Indep. Sch. Dist

In Houston Fed'n of Teachers v. Houston Indep. Sch. Dist., 730 S.W.2d 644, 646, 30 Tex. Sup. Ct. J. 379 (Tex. 1987), the supreme court reviewed the decision of the court of appeals that dissolved a temporary injunction barring a school district from lengthening the school day and dismissed the underlying suit. Houston Fed'n of Teachers, 730 S.W.2d at 645. The district court recognized that the Commissioner of Education was not authorized to order immediate injunctive relief and that if the teachers had started the administrative process, the teachers would have suffered irreparable harm by the time injunctive relief could be obtained from the courts. Id. The court of appeals held that the teachers should have first pursued their claim through the administrative process before resorting to the courts, and did not address the district court's finding of severe, immediate and irreparable harm that formed the basis of the temporary injunction. Id. The supreme court stated that parties should not be required to pursue the administrative process if the parties would suffer irreparable harm and if the agency is unable to provide relief. Id. Under these circumstances, the courts may properly exercise their jurisdiction in order to provide an adequate remedy. Id. Because the court of appeals did not disturb the district court's finding, the supreme court held that the court of appeals erred in dismissing the suit and remanded the cause to the court of appeals to determine whether the district court had abused its discretion in granting the temporary injunction. Id.