In Fudge v. Haggar, 621 S.W.2d 196, 198 (Tex. App.--Texarkana 1981, writ ref'd n.r.e.), the court held that a police department properly complied with the predecessor statute to Subchapter B by presenting a terminated officer with a letter of complaint, signed by his supervisor, prior to terminating him. 621 S.W.2d at 198.
In reaching this conclusion, the court stated, "In this case we deal with an internally generated complaint. Even though the initial information received by the police department was external, coming from the Dallas County Sheriff's Office, the entire investigation began within the police department." Id.
The court went on to state that the supervisor's signed letter of complaint "was in compliance with the predecessor to Subchapter B." Id.
The implication of Fudge is that Subchapter B applies to both externally generated and internally generated complaints, so that any complaint against a law enforcement officer, including complaints originating from within the police department, "must be reduced to writing and signed by the person making it." Id.