There’s only one Tyler case in this week’s orders from the Texas Supreme Court. It’s a denial of the petition for review in Geiger v. Williams. Geiger is prisoner’s civil rights suit against five TDCJ employees and six employees of UT Medical Branch. In December, 2007, the Tyler court had affirmed the dismissal of Geiger’s claims because Geiger failed to comply with Tex. Civ. Prac. & Rem Code Chapter 14. What’s interesting to me is that the Tyler court’s April, 2008, decision in Archer held that Chapter 14 doesn’t apply to claims against individual employees. I’m wondering if Geiger made this point, or if Geiger’s claims were otherwise barred by sovereign immunity. Archer’s claims fit within the Tort Claims Act waiver of immunity because they involved the use of a motor vehicle by the TDCJ employees.