In City of Galveston v. Shu, 607 S.W.2d 942, 946 (Tex. Civ. App.-Houston 1st Dist. 1980, no writ), the First Court of Appeals found that the City of Galveston had actual notice of an accident between plaintiff's vehicle and a Galveston Police Department van. 607 S.W.2d at 946.
The appellate court reasoned that Galveston had actual notice because Galveston police officers investigated the accident, took witness statements, and photographed the accident scene. Id. at 945-46.
Notably, the court held that "before notice to an agent or representative will be imputed to his principal or superior, it must have come to him at a time when he was engaged in the business of his principal under circumstances imposing upon him the reasonable duty of making the facts known to his superior." Id. at 945.