The Texas Court of Appeals has ruled on a significant case involving claims against school employees regarding the discipline of a minor student. The court's decision affects how schools manage student discipline and the legal protections for students with disabilities. The case, titled Max Curry, Jr. and Angela Sneed-Curry, A/N/F C.J.C., a Minor v. Shawn Dally, Brian White, Natasa Wroblski, and Katie Gordon, was filed under docket number 02-25-00477-CV and was decided on May 14, 2026.

The appeal arose from a dispute involving the Mansfield Independent School District (MISD) and several of its employees. The parents of a student, Jerry, alleged that the employees acted outside their official authority while disciplining their child. This case highlights the complexities of legal immunity for school employees and the rights of students, particularly those with disabilities.

The parties involved in this case include Max Curry, Jr. and Angela Sneed-Curry, who are acting as next friends for their son Jerry, a minor with a 504 plan. The defendants are four employees of the Mansfield Independent School District: Shawn Dally, Brian White, Natasa Wroblski, and Katie Gordon. The Currys filed a declaratory-judgment suit against these employees, claiming they failed to follow proper procedures when disciplining Jerry, who has a disability.

The dispute escalated when the Currys alleged that the school employees used excessive force and failed to report suspected abuse as required by law. The trial court granted the employees' plea to the jurisdiction, dismissing the claims against them. The Currys then appealed this decision, arguing that they had sufficiently pleaded claims of ultra vires actions, which are actions taken by government officials outside their authority.

In its ruling, the Texas Court of Appeals affirmed the dismissal of the claims against three of the employees, namely White, Wroblski, and Gordon. However, the court reversed the dismissal of certain claims against Dally, allowing those claims to proceed. Justice Elizabeth Kerr wrote the opinion for the court, stating, "We conclude that the trial court properly dismissed the failure-to-report claims against the Employees, we affirm that part of the dismissal order." The court also noted that the Currys had adequately pleaded ultra vires claims against Dally regarding the use of restraint and time-out techniques.

The court's ruling is significant as it clarifies the legal standards for ultra vires claims against school district employees. The court emphasized that employees do not have immunity from suit for properly pleaded ultra vires claims. This means that if a school employee is found to have acted outside their authority or failed to perform a required duty, they can be held accountable.

One key aspect of the ruling was the court's interpretation of what constitutes an ultra vires claim. The court explained that a valid ultra vires claim must show that an employee failed to perform a purely ministerial act or acted outside their discretionary authority. The Currys alleged that Dally improperly restrained Jerry and used aversive techniques during discipline, which the court found to be sufficient to support their claims.

The ruling has implications for how schools handle disciplinary actions, especially for students with disabilities. It reinforces the idea that school employees must adhere to established procedures and guidelines when dealing with students who require special accommodations. Furthermore, the court's decision may encourage parents to hold school officials accountable when they believe their children are subjected to improper treatment.

Moving forward, this case sets a precedent for future claims against school employees regarding the treatment of students with disabilities. The court's decision could lead to increased scrutiny of disciplinary practices in schools and may prompt school districts to review their policies and training programs for staff regarding the treatment of students with special needs.

As for the next steps, the Currys may replead their claims related to corporal punishment against Dally, as the court indicated that there is a possibility for these claims to be amended. The case has not been fully resolved, and further proceedings will take place in the lower court to address the remaining claims against Dally.

In conclusion, the Texas Court of Appeals' ruling in this case highlights the ongoing legal challenges surrounding student discipline in schools, particularly for students with disabilities. It emphasizes the importance of adhering to legal standards and the accountability of school officials when it comes to the treatment of students.