A Texas court has reversed a lower court's decision that allowed two applicants to challenge the automatic denial of their social worker licenses due to prior felony convictions. The Texas Court of Appeals, 15th District, ruled on June 4, 2026, in the case of Texas State Board of Social Worker Examiners v. Katherin Youniacutt and Tammy Thompson (Docket No. 15-25-00064-CV). This ruling affects individuals seeking social work licenses in Texas who have prior felony convictions involving violence.
The court's decision is significant as it upholds a law that mandates the automatic denial of social worker licenses for applicants with certain felony convictions. This ruling reinforces the state's stance on protecting vulnerable populations from potential harm by licensed professionals.
Background
The Texas State Board of Social Worker Examiners and the Texas Behavioral Health Executive Council are responsible for regulating social workers in Texas. Under Section 108.052(2) of the Texas Occupations Code, a licensing authority must automatically deny an application for a social worker license if the applicant has been previously convicted of a felony involving the use or threat of force.
Katherin Youniacutt and Tammy Thompson, the plaintiffs in this case, both hold master's degrees in social work and met other licensing requirements. However, their applications were denied due to prior assault convictions from the 2000s. Youniacutt's conviction stemmed from an incident where she hit a police officer with a car during a DUI stop, while Thompson's involved beating a man with a baseball bat. Both women claimed to have overcome their past issues with substance abuse and had received numerous letters of recommendation supporting their applications.
After their applications were denied, Youniacutt and Thompson filed a lawsuit against the Texas State Board of Social Worker Examiners and the Texas Behavioral Health Executive Council. They sought declaratory and injunctive relief, arguing that Section 108.052(2) violated their constitutional rights to due process and equal protection under the law.
The Ruling
The Texas Court of Appeals ruled that the plaintiffs' constitutional claims were facially invalid. The court found that both the due process and equal protection challenges to Section 108.052(2) did not hold merit. The justices concluded that the automatic ban on licensing applicants with certain felony convictions was rationally related to the government's legitimate interest in protecting vulnerable citizens.
The court stated, "We conclude Plaintiffs’ due course of law and equal protection challenges to Section 108.052(2) are facially invalid."
The ruling was delivered by Justice Scott K. Field, with the panel including Chief Justice Brister and Justice Farris. The court determined that the statute's purpose was to ensure the safety of individuals who may be served by licensed social workers, which justified the automatic denial of applications based on felony convictions.
Impact
This ruling sets a precedent for future cases involving the licensing of social workers and other health care professionals with felony convictions in Texas. It reinforces the state's authority to impose strict regulations on licensing to protect public safety, particularly for vulnerable populations. The decision may discourage other potential applicants with similar backgrounds from pursuing social work licenses, knowing that they may face automatic disqualification.
Moreover, the ruling highlights the balance between individual rights and public safety concerns. While the plaintiffs argued for the opportunity to demonstrate their rehabilitation and fitness for the profession, the court sided with the legislature's decision to impose categorical bans for specific criminal histories.
What's Next
The plaintiffs may seek to appeal this ruling to a higher court, but details were not available in the court filing regarding any plans for further legal action. As of now, there are no related cases pending that could impact this ruling.