1:00 P.M.  
SCHOOL BOARD  
JANUARY 28, 2025  
BOARD AUDITORIUM AND BOARD SERVICES CONFERENCE ROOM  
4400 WEST 18TH STREET  
HOUSTON, TEXAS 77092  
THE PURPOSE OF THE HOUSTON INDEPENDENT SCHOOL DISTRICT SCHOOL BOARD  
IS TO REPRESENT THE VISION AND VALUES OF THE COMMUNITY, AND CONSISTENT  
WITH THAT, GOVERN THE ADMINISTRATION OF THE HOUSTON INDEPENDENT  
SCHOOL DISTRICT IN A MANNER THAT BEST ALLOWS FOR THE IMPROVEMENT OF  
ACADEMIC OUTCOMES FOR ALL THE STUDENTS WE SERVE. THE SCHOOL BOARD  
MUST BE ABLE TO DO ITS WORK OF GOVERNING, INCLUDING DELIBERATIONS AND  
DECISION-MAKING, IN ORDERLY MEETINGS HELD OPEN TO THE PUBLIC.  
IN ORDER TO (I) ENSURE WE CAN EFFICIENTLY ADDRESS THE NEEDS OF OUR  
STUDENTS, (II) ALLOW FOR NECESSARY DELIBERATIONS AND DISCUSSIONS TO  
OCCUR, (III) GIVE ALL MEMBERS OF THE PUBLIC AN OPPORTUNITY TO PARTICIPATE  
AND OBSERVE THE SCHOOL BOARD'S MEETINGS, AND (IV) PROVIDE APPROPRIATE  
TRANSLATION SERVICES FOR NON-ENGLISH SPEAKING MEMBERS OF THE HISD  
COMMUNITY, WE WILL ADHERE TO THE FOLLOWING RULES AND NORMS:  
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PUBLIC COMMENT DURING SCHOOL BOARD MEETINGS WILL ONLY BE  
AVAILABLE TO THOSE PERSONS WHO HAVE SIGNED UP TO SPEAK PRIOR TO  
THE MEETING TIME PER CURRENT PROTOCOL.  
•
VERBAL AND OTHER DISRUPTIONS BY PERSONS DURING THE SCHOOL BOARD  
MEETINGS ARE NOT ACCEPTABLE AS THEY INHIBIT THE BOARD’S ABILITY TO  
CONDUCT BUSINESS AND THE PUBLIC’S ABILITY TO OBSERVE THOSE  
PROCESSES. PERSONS WHO PARTICIPATE IN SUCH BEHAVIOR WILL BE GIVEN  
ONE WARNING AND IF THE BEHAVIOR IS REPEATED, THEY WILL BE ASKED TO  
LEAVE THE MEETING.  
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SEATING IN THE BOARD ROOM IS AVAILABLE ON A FIRST COME, FIRST SERVED  
BASIS FOR ALL PERSONS, INCLUDING THOSE WHO HAVE SIGNED UP TO SPEAK  
DURING PUBLIC COMMENT. OVERFLOW SEATING MAY BE AVAILABLE, ALSO  
ON A FIRST COME, FIRST SERVED BASIS.  
A MEMBER OF THE COMMUNITY WISHING TO ADDRESS THE BOARD MAY DO SO IN  
PERSON OR BY LIVE VIDEO VIA ZOOM. FOR EITHER METHOD, A PERSON WHO  
WISHES TO ADDRESS THE BOARD MUST REGISTER WITH THE BOARD SERVICES  
OFFICE BY 12:00 P.M. THE DAY BEFORE THE MEETING. ANY SUPPORTING  
INFORMATION (E.G., HANDOUTS) REGARDING THE COMMUNITY MEMBER'S  
CONCERN SHALL BE FILED WITH BOARD SERVICES BY 12:00 P.M. THE DAY BEFORE  
THE MEETING. FURTHER DETAILS AND INSTRUCTIONS FOR REGISTERING TO SPEAK  
ARE AVAILABLE AT: HTTPS://WWW.HOUSTONISD.ORG/PAGE/32478.  
THE AGENDA PACKET FOR THIS MEETING IS AVAILABLE AT  
HTTPS://HOUSTONISD.LEGISTAR.COM/CALENDAR.ASPX.  
THE BOARD MEETING MAY BE VIEWED VIA:  
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AT&T UVERSE HISD TV CHANNEL 99  
COMCAST HISD TV CHANNEL 18  
WEBSITE HTTPS://WWW.HOUSTONISD.ORG/LIVETV  
A RECORDING OF THE MEETING WILL BE MADE AVAILABLE AT:  
HTTPS://HOUSTONISD.LEGISTAR.COM/CALENDAR.ASPX  
THE ITEMS ON THIS AGENDA MAY BE TAKEN IN ANY ORDER.  
NO AGENDA OR DISTRICT BUSINESS WILL BE DISCUSSED EXCEPT AS NOTICED  
BELOW AND ANY ACTION WILL OCCUR IN THE ROOM OPEN TO THE PUBLIC. IT IS  
THE INTENT OF THE DISTRICT TO HAVE, AND THE MEETING WILL HAVE, A QUORUM  
PHYSICALLY PRESENT AT THIS LOCATION. THE ABOVE LOCATION WILL BE  
EQUIPPED WITH VIDEO CONFERENCE EQUIPMENT.  
Notice is hereby given that a meeting of the Board of Managers of Houston Independent  
School District be held on January 28, 2025, for the purpose of considering and taking action  
on all matters on the agenda for the meeting, including approval of an agreement with the law  
firms of Thompson & Horton, LLP; Eiland & Bonnin, PC; and O’Hanlon, Demerath & Castillo,  
PC, as special counsel to perform all legal services necessary to recover damages sustained  
by the District related to youth social media usage and any other action that may be  
necessary to pursue the best interests of the District in related litigation on a contingent fee  
basis.  
The purpose of the agreement is to pursue any and all available causes of action in Multi  
District Litigation 3047 or JCCP 5255 seeking to recover damages due to youth social media  
usage and addiction sustained by Houston Independent School District. By way of this  
agreement, Houston Independent School District seeks to recover damages, court costs,  
penalties, and other relief under applicable law.  
Thompson & Horton, LLP, is a full-service school law firm whose mission is to provide the  
highest quality personalized legal service to public and private schools, institutions of higher  
education, local governments, and private individuals and companies. Thompson & Horton  
attorneys have unique and specialized qualifications based on several hundred years of  
combined experience. Leaders in the field, their attorneys have been directly involved in many  
of the most significant court cases, administrative decisions, and public policy developments  
affecting their clients over the past 40 years. Thompson & Horton has represented the District  
for over 10 years. Thompson & Horton discussed the social media litigation with the District in  
January 2025. Thompson & Horton introduced Eiland & Bonnin to the District to consider the  
social media litigation in January 2025. Thompson & Horton included O’Hanlon, Demerath &  
Castillo in conversation with the District to consider the social media litigation in January 2025.  
Eiland & Bonnin, PC, engages in complex contingent fee litigation which has required the  
investment of hundreds of thousands to millions of dollars of litigation expenses. Lawyers in  
the firm have served in past MDL leadership committees. The firm has worked in many  
high-profile litigations like the MGM Grand Las Vegas Mass Shooting, Syngenta GMO Corn,  
and BP Texas City Refinery Explosion. After 20 years of service as a member of the Texas  
House of Representatives for Districts 23 & 24, Craig Eiland has a unique understanding of  
what elected officials and public entities are confronted with when navigating complex  
litigation. Mr. Eiland regularly advises multiple Texas school districts in litigation. Thompson &  
Horton has represented the District for over 10 years. The inception of the relationship  
between Eiland & Bonnin and the District began when Thompson & Horton introduced Eiland  
& Bonnin to the District in January 2025 to consider the social media litigation.  
O’Hanlon, Demerath & Castillo, PC, regularly serves school districts across the state of Texas  
in a general counsel capacity and maintains a principal office in Austin, Texas and also offices  
in Pharr, San Antonio and Fort Worth. The firm has litigated statewide high profile public  
education related cases such as the No Pass No Play, the A-F litigation and multiple  
Edgewood decisions related to the school finance system. After serving as General Counsel  
for the Texas Education Agency and litigating various high-profile issues for the public  
education system for the Attorney General of Texas, Kevin O’Hanlon founded the firm in 1992  
to serve the needs of Public Entity clients. Justin Demerath operates a contingent fee litigation  
practice within the firm that regularly represents public entities on a contingent fee basis, often  
in the scope of property insurance disputes. Additionally, his practice has recovered millions  
of dollars in recovery in high-profile multi-district litigations, including Syngenta GMO Corn,  
General Motors ignition switch recall, Trans-vaginal mesh, and NFL concussion litigation, as  
well as serving in leadership of cases that garnered national attention like the Sutherland  
Springs Mass Shooting. Thompson & Horton has represented the District for over 10 years.  
O’Hanlon, Demerath & Castillo has previously intermittently represented the District in various  
areas of practice as external counsel for more than 15 years. Thompson & Horton included  
O’Hanlon, Demerath & Castillo in conversation with the District in January 2025 to consider  
the social media litigation.  
Thompson & Horton has served as legal counsel to Houston Independent School District for  
over 10 years. Thompson & Horton has not previously represented Houston Independent  
School District on a contingency fee arrangement. Eiland & Bonnin has not previously  
represented Houston Independent School District on a contingency fee arrangement. Eiland &  
Bonnin has not previously represented Houston ISD in any capacity. O’Hanlon, Demerath and  
Castillo has previously intermittently represented the District in various areas of practice as  
external counsel for more than 15 years. O’Hanlon, Demerath and Castillo has not previously  
represented Houston Independent School District on a contingency fee arrangement.  
Thompson & Horton, LLP, Eiland & Bonnin, PC, and O’Hanlon, Demerath & Castillo, PC  
have, and continue to represent, claimants with competence and professionalism.  
The specialized legal services, advancement of significant expenses, and compensation on a  
contingent fee basis required by this agreement cannot be performed by the attorneys and  
supporting personnel of Houston Independent School District because the District does not  
currently employ attorneys who have specialized knowledge and experience regarding  
Multi-District Litigation and analysis and legal remedies under both Texas and federal law on  
a contingent fee basis. In addition, the District has not budgeted the financial resources  
necessary to advance the significant litigation expenses required by this type of litigation nor  
to compensate competent and experienced attorneys and staff regarding Multi-District  
Litigation as District employees or to reasonably compensate a firm in private practice with the  
necessary experience under a contract providing for payment on an hourly basis without  
contingency.  
Due to the complexity of the matter and expected difficulties in performing the legal work for  
this matter, the risk of no recovery, the expected expenses, including expert witness fees and  
other litigation costs, a reasonable hourly fee for a firm in private practice to prosecute this  
matter would exceed the amount for which the District would be able to adequately budget  
and expend financial resources. The District also does not have the financial resources  
required to pay the additional, significant costs of implementing appropriate infrastructure and  
technology necessary to fully and properly perform the needed legal services. The District  
also does not have the financial resources required to properly pursue its claims and causes  
of action, including to retain independent experts as testifying witnesses and to finance all  
costs of litigation through final resolution of the matter. Additionally, many law firms that  
handle large, complex matters strictly on an hourly basis have institutional clients, including  
social media corporations, insurance companies, and social media corporations; and it would  
be difficult to find a firm with experience in this area that does not have a conflict of interest  
that would hinder the firm’s ability to effectively represent the District. The proposed law firms  
have certified that they have no such conflict of interest in representing Houston ISD.  
The legal services cannot be reasonably obtained from attorneys in private practice charging  
hourly fees without contingency because a contract to pay attorneys on an hourly basis  
without contingency would represent an additional and significant cost to Houston  
Independent School District. Furthermore, the District would be responsible for payment of all  
costs and expenses of the litigation through appeals, including to retain independent experts  
as testifying witnesses and to finance all discovery expenses and other costs of litigation  
through final resolution of the matter. The District does not have the financial resources  
necessary to pay for these additional and significant expenses necessitated by this social  
media multi-district litigation.  
Thompson & Horton, LLP; Eiland & Bonnin, PC; and O’Hanlon, Demerath & Castillo, PC, will  
be compensated on a contingent fee basis. Entering into the proposed agreement is in the  
best interests of the residents of Harris County, Texas. The District has sustained significant  
damages due to youth social media usage and addiction and for which there exists a potential  
recovery from the perpetrating social media corporations. Thompson & Horton, LLP; Eiland &  
Bonnin, PC; and O’Hanlon, Demerath & Castillo, PC, possess the specialized skills,  
knowledge, experience, financial, and technological resources needed to competently and  
fully pursue maximum potential recovery of the District's damages. Furthermore, the proposed  
agreement enables the District to pursue its legal remedies without diverting essential monies  
and resources from the ongoing needs and operations of its students, staff, and community at  
large. In addition, the proposed agreement shifts the financial risk and burden of litigation  
costs and expenses to Thompson & Horton, LLP; Eiland & Bonnin, PC; and O’Hanlon,  
Demerath & Castillo, PC, with the District owing no such monies to the law firms unless and  
until it recovers monies. Moreover, Texas statutory and common law provide for penalty  
damages and for recovery of court costs, and for recovery of attorneys' fees for certain of the  
District's claims, including for breaches of contract.  
Additionally, time is of the essence in the provision of these legal services. Potentially  
impending legal deadlines require urgent action by counsel.  
1:00 P.M. – BOARD AUDITORIUM – OPEN SESSION  
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CALL TO ORDER  
SPEAKERS TO AGENDA ITEMS  
RECESS TO CLOSED SESSION UNDER SECTIONS 551.004 THROUGH 551.089 OF  
THE TEXAS GOVERNMENT CODE FOR THE PURPOSES LISTED IN THIS NOTICE  
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RECONVENE IN OPEN SESSION  
CONSIDERATION AND POSSIBLE ACTION ON MATTERS DISCUSSED IN CLOSED  
SESSION  
HEARING ITEMS  
1.  
2.  
3.  
Rebecca Williams, Teacher, Navarro Middle School  
HFT v HISD (Employee Consultation Process Policy)  
Pondarosia Griggs, employee, Forest Brook Middle School  
AGENDA  
4.  
Consideration And Adoption Of Resolution Approving Contingent Fee Legal Services  
Agreement, Including Findings Needed For Submission Of Contingent Fee Legal  
Services Agreement And Request For Expedited Review By The Texas Attorney  
General  
5.  
Consideration And Adoption Of Contingent Fee Legal Services Agreement With  
Thompson & Horton, LLP; Eiland & Bonnin, PC; And O'Hanlon, Demerath & Castillo,  
PC  
CLOSED SESSION  
Personnel  
a)  
Deliberate the duties of the superintendent of schools, chief officers, deputy chief  
officers, executive directors, principals, employees, and board members; evaluations of  
the superintendent; consideration of compensation, and contractual provisions of  
same.  
b)  
Consider and approve proposed appointments, reassignments, proposed terminations,  
terminations/suspensions, contract lengths, proposed nonrenewals, renewals, and  
resignations/retirements of personnel including teachers, assistant principals,  
principals, chiefs, division superintendents, senior executive directors, executive  
directors, directors, and other administrators, and, if necessary, approve waiver and  
release and compromise agreements.  
c)  
d)  
Hear complaints against and deliberate the appointment, evaluation, and duties of  
public officers or employees and resolution of same.  
Consideration of Hearing Examiner’s Recommendation, Rebecca Williams, Teacher,  
Navarro Middle School  
e)  
f)  
Dispute Resolution Hearing, HFT v HISD (Employee Consultation Process Policy)  
Dispute Resolution Hearing, Pondarosia Griggs, employee, Forest Brook Middle  
School  
Legal  
a)  
Matters on which the district’s attorney’s duty to the district under the Code of  
Professional Responsibility clearly conflicts with the Texas Open Meetings Law,  
including specifically any matter listed on this agenda and meeting notice.  
b)  
c)  
d)  
Pending or contemplated litigation matters and status report.  
Update on federal law enforcement activity on February 27, 2020.  
Discuss participation in multi-district litigation involving youth social media usage and  
related litigation and entering into a contingency fee contract with Thompson & Horton,  
LLP; Eiland & Bonnin, PC; and O’Hanlon, Demerath & Castillo, PC, to represent the  
District (Texas Government Code §551.071).  
District Safety, Emergency Management, And Security Audits  
a)  
Discussion of district safety concerns, including districtwide intruder detection audit  
report findings and HB3 compliance.  
CLOSED SESSION AUTHORIZATION DURING MEETING  
If during the course of the meeting covered by this notice the board should determine  
that a closed or executive meeting or session of the board should be held or is  
required, then such closed or executive meeting or session as authorized by Chapter  
551 of the Texas Government Code (the Open Meetings Act) will be held by the board at  
the date, hour, and place given in this notice or as soon after the commencement of the  
meeting covered by this notice as the board may conveniently meet in such closed or  
executive session concerning any and all subjects and for any and all purposes  
permitted by Section 551.071 through Section 551.089 inclusive of said Open Meetings  
Act.  
Should any final action, final decision, or final vote be required in the opinion of the  
board with regard to any matter considered in such closed or executive session, then  
such final action, final decision, or final vote shall be at either:  
a) the open meeting covered by this notice upon the reconvening of this public  
meeting, or  
b) a subsequent public meeting of the board upon notice thereof, as the board shall  
determine.  
ADJOURN  
CERTIFICATE AS TO POSTING OR GIVING OF NOTICE  
On this 24th day of January 2025 at 5:00 p.m., this notice was posted on a bulletin  
board located at a place convenient to the public in the HMW Educational Support  
Center of the Houston Independent School District, the address of which is 4400 West  
18th Street, Houston, Texas, as well as on the district’s public web portal.  
Emily A. Smith, M.Ed.  
Executive Director, Board Relations  
Houston Independent School District