Sanchez V City of Poteet - Original Complaint
Sanchez V City of Poteet - Original Complaint
Sanchez V City of Poteet - Original Complaint
I. Introduction
1. The City of Poteet’ has chosen to condemn a home during the COVID- 19 pandemic because the
residents of the house occasionally use extension cords as wiring. Only this Court can prevent the City of
Poteet from acting with venal disregard for the law and the lives of the Plaintiffs. By removing the
Plaintiffs from their home at this time, the City of Poteet is putting Denise Leal Sanchez and Stephen
Burgoyne at risk of transmission of a deadly illness. This is especially true for Mr. Burgoyne, a U.S. Navy
veteran, who suffers from Chronic Obstructive Pulmonary Disorder (COPD). The City’s quest to remove
the Plaintiffs from their home also violates Texas law, the U.S. Constitution and the City’s own COVID-
19 protocols. Plaintiffs seek emergency relief from this Court to prevent serious injury and damage.
2. The real reason the City of Poteet is seeking this bizarre and cruel action is that it wishes to
punish Plaintiff Denise Leal Sanchez for practicing her God-given First Amendment Right to question the
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government of the City of Poteet. For years, the City of Poteet has waged a battle with Ms. Sanchez. They
have charged her with a crime for speaking her mind at council meetings. They have banned from City
Hall indefinitely and without cause. They have cited her for numerous, largely frivolous, violations of
municipal ordinances. And, now, they seek to demolish her home. All of this is done out of spite and the
malignant desire to silence the voice of opposition to the leadership of this small town in Texas.
II. Parties
2. Plaintiff Denise Leal Sanchez is current city councilperson for the City of Poteet. She
resides in the City of Poteet at 749 Avenue E, Poteet, Texas 78065. Plaintiff Denise Leal Sanchez is
a current City Councilwoman of the City of Poteet. She is also a long time and vocal opponent of the
City’s practices. As a voter, taxpayer, and an occasional city official, she has fought the current City
Administrator and the leaders of the City of Poteet. She has questioned the managerial decisions of
Administrator Jiminez and asked difficult questions concerning the City’s finances. She has demanded
that the Chief of Police meet his obligations to be a licensed police officer. In short, she has demanded
that the City of Poteet live up to its obligations under the law. As a punishment, the City has targeted Ms.
Sanchez with selective and arbitrary enforcement of their ordinances. They have banned her from City
Hall – except during Council meetings. They have sought to remove her from her own property because
her home is “unsafe” even though her home is exactly in the same state of disrepair as hundreds of other
homes in Poteet. Now, during the middle of a pandemic, the City seek to oust her from her home solely
3. Plaintiff Sanchez is being injured by the Defendants in the following ways: 1) she is
being removed or threatened with removal from her home during a contagious pandemic, when
many other municipal matters have been stayed; 2) she has been targeted with selective,
arbitrary, and punitive enforcement of City ordinances and police powers because she is vocal
opponent of the leadership of the City of Poteet; and, 3) she has been banned from entering City
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Hall where residents pay their utility bills and engage in other necessary municipal business,
because she expressed her First Amendment right to question her government. In sum, the City
has targeted Plaintiff Sanchez for impermissible purpose, to retaliate against her because of
opposition to the City’s policies. These actions, in total, injure Ms. Sanchez’s First & Fourteenth
Amendment Rights. As a consequence of the City’s actions, Ms. Sanchez has suffered repeated
bouts of illness and, at least, one hospitalization. She is on the verge of being removed from her
home illegally. The City has threatened that her home will be demolished for minor infractions
of the building codes. And, now, the City has chosen to place her health directly at risk by
4. Plaintiff Steven Burgoyne resides with Ms. Sanchez at 749 Avenue E, Poteet, Texas.
Mr. Burgoyne is a disabled U.S. Veteran with Chronic Obstructive Pulmonary Disease (COPD).
After previously being intermittently homeless, Mr. Burgoyne has found a safe place to live in
Ms. Sanchez’s home. Since Mr. Burgoyne has moved into Ms. Sanchez’ home, his health has
improved and he is receiving regular services from the Veterans Administration. When he moved
in with Ms. Sanchez, he could not walk. Now, he is ambulatory. COPD is a chronic respiratory
illness. Mr. Burgoyne is injured by the actions of the Defendants because he faces homelessness.
In addition, by operation of the City’s intention to hurt Ms. Sanchez he will be placed at risk of
contracts COVID-19, he faces serious injury and the prospect of death. Mr. Burgoyne would
prefer to live with Ms. Sanchez, because he knows that in her home he is safe and free from
5. The Estate of Rubin Leal is the owner of 749 Avenue E, Poteet, Texas.
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6. Defendant the City of Poteet is a Texas general law municipality of type A. It may be
served at 491 Avenue E, Austin, Texas 78701. The City of Poteet is in the Western District of
Texas.
7. Defendant Eric A. Jiminez is the City Administrator of the City of Poteet. He is being
sued in his official capacity. He may be served at 491 Avenue E, Austin, Texas 78701. Mr.
8. Defendant Bruce Hickman is the Chief of Police of the City of Poteet. He is being sued in
his official capacity. He may be served at 491 Avenue E, Austin, Texas 78701. Mr. Hickman
9. Defendant William “Bill” Lay is an inspector and holder of various municipal offices for
the City of Poteet. He is being sued in his official capacity. He may be served at 491 Avenue E,
Austin, Texas 78701. Mr. Lay resides in the Western District of Texas.
10. The Honorable Bill Gamez is a municipal judge for the City of Poteet and a defendant in
this action. He is being sued in his official capacity. He may be served at 491 Avenue E, Austin,
11. Plaintiffs’ complaint arises under the United States Constitution and federal
statutes. This court has jurisdiction over this action under 28 U.S.C. §§ 1331, 1343(a), 1367(a)
12. Venue is proper in the Western District of Texas. 28 U.S.C. § 1391(b)(1) as all
13. Plaintiffs seek declaratory and injunctive relief pursuant to 28 U.S.C. §§ 2201 and 2202.
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IV. Facts
15. In the afternoon of Friday May 22, 2020, the City cited Ms. Sanchez for trespassing on
her own property. A threat to remove Ms. Sanchez by force was issued along with the citation.
Ms. Sanchez will be removed from her property on Tuesday May 26, 2020. When she is
removed, the condemnation of her property will begin, including its demolition.
16. Mr. Burgoyne will have no place to live that safe and free from abuse should he be
removed from 749 Avenue E. He has chronic respiratory disorder, which places him at high-risk
for serious injury or death related to transmission of COVID-19. Should he be removed from a
17. The Estate of Rubin Leal is at risk of having its property destroyed illegally and
unconstitutionally.
18. If this Court does not issue immediate emergency relief enjoining the City from acting,
irreparable harm will occur and her home will be lost. The American Dream of homeownership
only means something, if property rights are respected and courts act to prevent harm.
19. The tragic part of all of this, is that it stems from Ms. Sanchez’s constitutional right to
question her government. The City of Poteet is only acting in this manner as retaliation and
punishment for Ms. Sanchez strong dissent against the leadership of this town.
20. Denise Leal Sanchez is a current city councilperson of the City of Poteet.
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21. Poteet is a general law city of Texas of type 4. It is comprised of a city council of 5
22. Denise Leal Sanchez is also frequent and vocal opponent of the City of Poteet’s policies
and actions. Before her current term as a city councilor, she attended the City of Poteet’s
meetings frequently and would often question the City of Poteet on its policies. Sometimes this
questioning was impertinent. Sometimes this questioning was angry. But, Ms. Sanchez’s
opposition and questioning of the leadership of the City of Poteet was always based on what she
believed was in the best interest of voters and taxpayers of the City of Poteet. These questions
23. Denise’s questions have often caused real embarrassment for the City of Poteet and its
leaders.
24. For example, Ms. Sanchez raised doubts about the hiring of Defendant Jiminez as City
Administrator because of his separation from employment as a police officer for the City of
Seguin. Specifically, Seguin’s Chief of Police, Keven Kelso, alleged that on the morning of
September 23, 2016, Defendant Jiminez was involved in a domestic dispute with his girlfriend
while he was off duty. Defendant Jiminez was allegedly intoxicated. During the dispute, Mr.
Jiminez allegedly tazed his girlfriend multiple times. This alleged incident raised serious
concerns about Mr. Jiminez’s employment as City Administrator for the City of Poteet. Ms.
Sanchez raised those concerns and asked that this issue be placed on the agenda for the City
25. In addition, Ms. Sanchez raised questions about the Chief of Police, Bruce Hickman,
defendant in this cause of action. As a condition of his employment as Chief of Police of Poteet,
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Plaintiff Sanchez believed that Mr. Hickman was required to obtain his master peace officer’s
certification. This issue was placed on the council agenda, which lead to vigorous discussions
26. There are many more times in which Ms. Sanchez has angered the leaders of Poteet by
27. As a result, the City of Poteet and its leaders, Defendants here, have waged a retaliatory
war against Plaintiff Sanchez that has included the most recent illegal attempt to demolish her
family home.
28. Before her current term of office in the City of Poteet, Ms. Sanchez questioned a
member of the City Staff. This questioning was allegedly done in a rude manner. Ms. Sanchez
charged with a crime as a result of this altercation. Ms. Sanchez never physically threatened any
29. As a consequence of her arrest, Ms. Sanchez was banned from City Hall. The City also
sought prosecution of Ms. Sanchez’s supposed crimes. The City alleged it had video and
witnesses that would corroborate their claims that Ms. Sanchez broke the law.
30. In towns like Poteet, City Hall is not only the seat of government, but it is also the utility
provider. As a consequence of the banning, Ms. Leal could not directly pay her utilities or attend
to other municipal matters like obtaining permits for some home improvements.
31. After her election as a City of Poteet Councilperson, Ms. Leal was allowed to attend City
Hall solely for regular council meetings. She could not go to City Hall to inspect records, discuss
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matters with municipal staff, and pick up her mail or other communications. She is still
effectively banned from City Hall, which has hampered her ability to fulfill her role as a public
officer.
32. The City claimed it had a witness, but there was no witness. The City claimed that there
was video of the altercation. But, mysteriously, the video vanished when it was requested by Ms.
33. After more than a year, the pending criminal matter concerning her angry interaction with
34. Even after dismissal, Ms. Sanchez is still banned from City Hall except for council
meetings. She cannot go in to City Hall to pay her utility bills. She cannot go into City Hall to
obtain permits. If she goes in to City Hall during regular business hours, she is told that she will
35. The City has banned Ms. Sanchez from City Hall for exercising her First Amendment
Right to question her government. In addition, the City has banned Ms. Sanchez from City Hall
in retaliation and punishment against Ms. Sanchez for exercising her civil liberties. This injury
36. The City of Poteet in retaliation against Ms. Sanchez began a sham investigation into the
37. Ms. Sanchez resides in the home of her late father, Ruben Leal.
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38. In November of 2018, the City responding to two anonymous complaints began an
investigation into the home of Ms. Sanchez pursuant to the City’s Unsafe and Dangerous
Structure ordinance.
39. On November 21, 2018, the City of Poteet served an administrative search warrant on
Ms. Sanchez to inspect her home. Pursuant to the warrant, Defendant William “Bill” Lay began
his inspection of 749 Avenue E, Poteet, Texas. He found violations of the International Fire
Code that in his opinion rendered the structure unsafe. His recommendation was that “the house
be demolished for the safety of the occupants and the community.” Video and pictures of the
state of the home were taken during the investigation. These videos and pictures were published
40. On November 26, 2018, the City served notice on Denise Sanchez that she was
summoned to the Municipal Court to pull permits and come up with a plan to bring the home to
code.
41. On December 4, 2020, Ms. Sanchez responded to the notice and requested a hearing.
That hearing request was granted for December 18, 2018 at 2 PM.
42. At the hearing, the case was dismissed against Ms. Sanchez’s property.
43. Despite this setback, the City continued on. On March 7, 2019, the City served another
administrative warrant to search Ms. Sanchez’s property. No notice was given to her attorney of
record at that time. This attempt to re-file charges against Ms. Sanchez is barred by res judicata
or collateral estoppel.
44. A lengthy litigation ensued in which Ms. Sanchez would remedy the most dangerous
violations, including covering her water heater, clearing brush and weeds to prevent a fire
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hazard, and removed part of her carport that had fallen down. The home at 749 Avenue E was
safe. Despite this state of safety a hearing was set to make a final determination concerning the
safety of the home for January 28, 2020. Specifically, the Court ordered Ms. Sanchez: 1) to cut
the weeds and grass below 36 inches, and 2) to cease using extensions cords as permanent
wiring.
45. Using extensions cords as wiring should not lead to demolishing a house or condemning
the property. This is especially true when those wires are not frayed or dangerous.
46. The City gave Ms. Leal 90 days to move, relocate, or vacate her own property despite the
fact that none of the final code violations that needed remedy were sufficiently dangerous to
47. The City published its order on February 27, 2020 demanding that Ms. Sanchez leave her
property by May 20, 2020. May 20 is not 90 days from the effective date of the order.
48. However, Ms. Sanchez intended to finally rectify her writing situation. She had contacted
an electrician. This electrician tried to pull a permit from the City Hall of the City of Poteet, but
49. Ms. Sanchez, then, secured a master electrician, but by then COVID-19 had forestalled
50. The Governor declared that COVID-19 was pandemic and state emergency. This
emergency has radically altered Texas life, including in courts throughout Texas. On March 13,
2020, Governor Abbott declared that COVID-19 poses an imminent threat of disaster. On March
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19, 2020, Dr. John W. Hellerstadt, Commissioner of the Department of State Health Services
declared a state of public health disaster. Also on March 19, 2020, the Governor closed schools
temporarily. On April 27, 2020, the Texas Supreme Court also issued an order that “[a]ll
deadlines, whether prescribed by statute, rule, or order, that expired or would have expired
between March 13, 2020, and June 1, 2020, are extended until July 15, 2020.” Texas Supreme
Court, “Twelth Emergency Order Regarding the COVID-19 State of Disaster”, Misc. Docket No.
20-9059, April 27, 2020. On May 12, 2020, the Governor renewed his disaster declaration of the
previous two months. In his words, “a state of disaster continues to exist in all counties due to
COVID-19.”
51. There is a statutory deadline associated with judicial review municipally-adopted “unsafe
& dangerous structures” ordinances. In general, there is a 30 day time limit to seek review in
Texas district court of a municipal court order issued pursuant to said ordinances. Tex. Local
Gov’t Code § 214.0012. The deadline to seek review would have expired in March 20, 2020, at
the earliest.
52. However, the Texas Supreme Court has stated that any statutory deadline that occurs
between March 13, 2020 and June 1, 2020 are extended until July 15, 2020. The deadline to seek
judicial review has not elapsed and will not elapse until, at least, July 15, 2020.
53. The City of Poteet itself has sought to protect itself from COVID-19. In fact, the City of
Poteet’s municipal officers, including the Honorable Bill Gamez, Defendant in this cause, adopted
a municipal court procedure, which “suspend[ed] any and all deadlines and procedures, whether
prescribed by statute, rule, or order for a period of time ending no later than 30 days after the
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Governor’s state of disaster has been lifted.” City of Poteet Municipal Court Letter, March 13,
2020.
54. The deadline to vacate in the court order is May 20, 2020. On May 12, 2020, the
Governor re-issued his state disaster proclamation concluding that “a state of disaster continues to
55. The disaster continues and so does Poteet’s suspension of court-ordered deadlines. The
56. Finally, all of this is of no judicial moment. The City’s illegal quest to punish Denise
Sanchez for her vocal opposition to its policies is barred by res judicata.
57. The City first sought its rights in a suit against Denise Sanchez in December of 2018,
Cause No. 59186. This case was dismissed for want of a jurisdictional defect. The City did not
58. The City brought the same claim alleging the same violations based on the same conduct
59. The facts, complaints, parties, and allegations are identical in each proceeding. The city is
barred by res judicata or collateral estoppel. “[A] litigant must avail [himself] of statutory
remedies that may moot [his] takings claim, rather than directly institute a separate proceeding
asserting such a claim.” Patel v. City of Everman, 361 SW 3d 600, 601 (Tex. 2012).
60. Plaintiff Sanchez relied on the public pronouncements of the Governor, Texas Supreme
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61. However, in the abundance of caution, Ms. Sanchez filed a motion to stay execution of
the municipal court before May 20, 2020. The motion cited the Governor’s disaster declaration
and the Texas Supreme Court executive order. The City filed a response to the motion. Ms.
Sanchez replied citing the City of Poteet’s adopted policy pertaining to deadlines of court orders.
62. On May 20, 2020, the Honorable Bill Gamez denied the motion to stay despite the
executive orders issued by the Governor, Supreme Court and the City’s own policy.
63. This denial of the stay is a clear abuse of discretion. With all due respect to Judge Gamez,
the defendant is acting without adherence to judicial principles that are “amounting to a judicial
usurpation of power or a clear abuse of discretion.” In re Volkswagen of Am., Inc., 545 F.3d 304,
64. As stated above, Ms. Sanchez has made an effort to remedy most if not all of the cited
violations. The last remaining issue was the use of extension cords as permanent wiring. This
may be a violation of the code, however, it is not dangerous enough to require this extraordinary
65. Regardless, as soon as it is safe to act, Ms. Sanchez has secured a master electrician to
bring the home to code. Improvements will be made to make the house safer.
66. The City’s dangerous desire to oust the Plaintiffs from their home is more hazardous than
F. Poteet and its Leaders are fueled by an Impermissible purpose to harm the Plaintiffs
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67. There are other homes in Poteet that are similar or more disrepair than 749 Avenue E.
These homes are complained of formally and informally to the City of Poteet. These homes are
not investigated or cited. These homes are not searched using administrative warrants. These
homes and their owners are not cited or charged with violation of the ordinance. These homes or
their owners do not live in fear of being forcibly removed from their home. Their homes will not
be condemned or destroyed. They will not have a lien placed on them for destruction of their
property. The Plaintiffs have been disparately treated compared to similarly situated residents
68. In the alternative, the Plaintiffs are a “class of one”. The City of Poteet has applied an
standard violates the equal protection clause, even if the Plaintiffs are the only members of a
class that is affected. Village of Willowbrook v. Olech, 528 U.S. 562, 564 (2000). (“Whether the
complaint alleges a class of one or of five is of no consequence because we conclude that the
69. There have been numerous departures from normal operating procedure.
70. The City of Poteet used anonymous and obviously fictitious complainants to begin an
71. The City did not use the proper notice to give Plaintiffs the time to prepare their defense
72. The City used an inspector who is not a certified inspector to formulate its opinion that
73. The City published the videos and pictures of its investigation on its official Facebook
page.
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74. After being dismissed, the City sought yet another investigation though that inquest was
75. The City sought administrative warrants multiple times based on incorrect, sworn
information on affidavits.
76. In total, the City searched Plaintiffs property 4 time over the course of 9 months. There
are criminals and drug houses in Poteet with fewer intrusions into their privacy than 749 Avenue
E.
77. The City was made aware that there had been Adult Protective Service (APS)
determination that the home was habitable and safe. In fact, there have been two APS
investigation pursuant to anonymous complaints for Stephen Burgoyne’s safety. None of those
investigations have ever found that the home was unsafe. APS determination of habitability
78. The City published in local papers its intent to remove Ms. Sanchez from her home
several times. This was done even though the City knew that Ms. Sanchez was represented. This
79. The City adopted COVID-19 protocols which stay any deadline of any court order and,
80. The State has issued the same suspension of court-ordered deadlines, and the City refuses
81. The City has refused to allow Ms. Sanchez to pull a permit in order to stay destruction of
her property. The City additionally refuse to all her electrician to pull a permit, stating that he
was not a master electrician. The City allowed other people to pull a permit who were not master
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electricians for similar work. In addition, the City allegedly engaged in ex parte communications
with the municipal judge concerning these matters in the attempt to influence his decision.
81. There are other deviations from normal legal procedure including the banning her
presence from City Hall based on groundless accusations. This charges were dropped and, yet,
82. The City stated that it had evidence concerning Ms. Sanchez assault of City staff, but that
84. The reason it is bizarre is that the City is poorly hiding its real purpose, to punish Ms.
Sanchez for her First Amendment right to express opposition to her government. It’s
justifications for action are pre-textual and belie a dangerous and impermissible purpose.
V. Causes Action
Count 1- Equal Protection Clause of the 14th Amendment to the US. Constitution
85. Plaintiffs incorporate by reference all preceding paragraphs as if fully set forth herein.
86. The choice by City of Poteet to remove the Plaintiffs from their home and demolish the
home discriminates against plaintiffs in violation of 14th Amendment to the U.S. Constitution. In
addition, the City of Poteet continues to purposefully treat the Plaintiffs unequally compared to
similarly situated residents of Poteet in violation of the equal protection clause. This
87.Plaintiffs incorporate by reference all preceding paragraphs as if fully set forth herein.
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88.The choice by City of Poteet to discriminate against Plaintiffs on the basis of creed violates
the Texas’ Equal Rights Amendment, which states “Equality under the law shall not be denied or
abridged because of sex, race, color, creed, or national origin.” Tex. Const. Art. I § 3a.
89. Plaintiffs incorporate by reference all preceding paragraphs as if fully set forth herein.
90.The choice by City of Poteet to engage in retaliation against the Plaintiff because of Ms.
Sanchez opposition to the City’s leadership is a violation of the First Amendment to U.S.
Constitution.
91. Plaintiffs incorporate by reference all preceding paragraphs as if fully set forth herein.
92.Plaintiff seeks judicial review of the City of Poteet’s illegal order to relocate, vacate, and
demolish 749 Avenue E pursuant to this Court’s supplemental jurisdiction of the state claims in
this action. Specifically, Plaintiffs ask for a stay of the order issued by the municipal court and
declaration that the house is habitable and meets the low requirements to avoid condemnation
and demolition.
93.Plaintiffs incorporate by reference all preceding paragraphs as if fully set forth herein.
94.Plaintiff seeks a Writ of Mandamus to invalidate the nugatory order of the municipal court
denying the motion to stay execution based on the extraordinary circumstances of COVID-19.
The municipal court’s failure to observe the Governor and Texas Supreme Court’s mandatory
suspension of deadlines associated with court orders is an abuse of discretion and failure to act
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within the bounds of municipal jurisdiction. In addition, the municipal court failed to follows its
own adopted procedure. Writ should issue demanding that the City of Poteet stay the execution
of its Court order, at least, until after the Governor’s declaration of emergency ceases.
95. Plaintiffs incorporate by reference all preceding paragraphs as if fully set forth herein.
96. The City of Poteet is seeking the destruction and confiscation of Plaintiffs property in
violation of the U.S. and Texas Constitution. The U.S. Constitutional takings provision states
"nor shall private property be taken for public use without just compensation." Fifth
Amendment, U.S. Constitution. The City of Poteet is taking the Plaintiffs’ property without just
compensation. “No person's property shall be taken, damaged or destroyed for or applied to
public use without adequate compensation being made, unless by the consent of such person;
and, when taken, except for the use of the State, such compensation shall be first made, or
secured by a deposit of money.” Tex. Const. Art. 1 § 17. The City of Poteet is or will damage
Plaintiffs’ property without compensation. The City has violated or will violate the takings
97. Plaintiffs incorporate by reference all preceding paragraphs as if fully set forth herein.
98. Plaintiffs will likely succeed on the merits, because the City of Poteet’s order is illegal and
its order denying the stay of the order is illegal. Plaintiffs will succeed on the merits because the
home at 749 Avenue is safe and will be made safer. The Plaintiffs will succeed on the merits
because the City is acting with an obvious impermissible purpose in the attempt to silence the
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99. Plaintiffs will suffer immediate and irreparable injury if the City of Poteet is not enjoined
from removing, relocating, vacating the residents of 749 Avenue E and, then, demolishing the
property. Plaintiff Sanchez will be irreparable harmed because she will be removed from her
home. The City will have successfully retaliated against her for exercising her First Amendment
Right to question and expressively oppose her government. She will experience immediate
irreparable injury because she will be made homeless in the middle of a dangerous pandemic that
places her health at risk. Plaintiff Burgoyne will experience the injury of being removed from his
home and facing serious injury or death associated with transmission of COVID-19. The estate
100. There is no harm to the City of Poteet, because there is no governmental need to enforce
null orders. In addition, the relative safety of the home far exceeds the danger outside of the
home during this pandemic. The worst case scenario for the City is that the order to remove,
relocate and vacate would be executed after the pendency of the epidemic. The best case scenario
for the City, it will become satisfied with the scope of work committed to the home and will not
need to expend resources in demolishing the home. The City can wait. The Plaintiffs cannot.
101. The injunction is in the public interest, because there is no public interest in the needless
expenditure of dollars in demolishing a home that will be brought up to code in short order.
102. Plaintiffs have no other adequate, plain, or complete remedy at all other than enjoining
103. Plaintiffs request that the Court enter a temporary injunction and, then, a permanent
injunction prohibiting Defendants the City of Poteet, et al., from taking any action to remove,
relocate, or vacate the premises of 749 Avenue E, Poteet, Texas 78065. In addition, the City and
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its agents should be enjoined from destroying, razing, or damaging the property at 749 Avenue
E. Finally, the City of Poteet must lift its ban on Ms. Sanchez from being able to enter City Hall
104. For the foregoing reasons, Plaintiffs respectfully request that Defendants be cited to
appear and answer and that the Court take the following actions and grant the following relief:
themselves entitled;
D. Any other or further relief, in law or equity that the Court determines that plaintiffs are
entitled to receive.
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