Texas

Cross v. State of Michigan in Texas Law

How Cross v. State of Michigan applies in Texas: state-specific rules, key cases, and bar exam notes for Contracts.

State Approach

Texas courts apply the principles of governmental immunity and consent in contract claims against the state, paralleling the outcomes of Cross v. State of Michigan. The state retains immunity unless it has waived this immunity expressly through legislation.

State Rule
In Texas, a governmental entity may only be sued for breach of contract if it has expressly waived its governmental immunity, typically outlined in statutes like the Texas Tort Claims Act.
Significant State Cases

Lloyds of London v. Gibbons

Held that governmental immunity does not apply when the government enters into a valid contract.

City of Tyler v. Likes

Clarified that governmental immunity can be waived but must be specifically stated in the contract and statutory language.

Tex. Dep’t of Transp. v. W. Interests, Inc.

The court emphasized the necessity of clear language in statutes for waiving immunity in contract disputes.

Comparison to Federal Law

Texas law mirrors federal principles found in cases like Cross v. State of Michigan regarding limiting governmental liability in contract disputes. However, Texas places greater emphasis on express waivers through legislation.

Bar Exam Note

Understanding the nuances of governmental immunity in contract cases is crucial for Texas bar exam candidates, as it frequently appears in exam questions.

Practice Pointers
  • Always check if the governmental entity has waived immunity through specific statutory language.
  • Review the relevant statutes, like the Texas Tort Claims Act, for potential waivers of immunity.
  • Pay attention to the specific terms of the contract to determine enforceability against the state.

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