AFLOA, LLC v. Texas Department of Motor Vehicles

Court of Appeals of Texas·Decided February 3, 2025·No. 15-24-00003-CV·Published

Opinion

ACCEPTED 15-24-00003-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 2/3/2025 10:14 AM Ron Beal CHRISTOPHER A. PRINE Professor Emeritus & Attorney at Law CLERK 2530 Wooddale Circle RECEIVED IN 15th COURT OF APPEALS Waco, TX 76710 AUSTIN, TEXAS (254) 366-4198 2/3/2025 10:14:02 AM ron_beal@baylor.edu CHRISTOPHER A. PRINE Clerk

15th Court of Appeals February 3, 2025 P.O. Box 12547 Austin, TX 78711

Re: AFLOA, LLC v. TMVD Cause No: 15-24-00003-CV Amicus Letter Brief

Dear Honorable Justices of the 15th Court of Appeals:

I am not being compensated by anyone for the preparation, writing, or filing of this amicus letter brief.

I am solely concerned about the integrity of the Texas Administrative Law system and the fairness of administrative proceedings for our fellow Texas citizens and entities doing business in this State.

I have to admit that I have never been exposed to such conduct or, more appropriately, lack of conduct of the parties’ attorneys and this Court. A failure of all involved prejudices the rights of all parties to simply reach the merits of this cause consistent with the law and in a timely manner.

Sua sponte action or lack thereof of this Court should not be exercised to punish the tardy advocate. The key principles to be protected include consistent upholding of the rule of law as to jurisdiction, and the automatic exercise of sua sponte power so all advocates are treated in the same manner.

Finally, delay and additional costs to the parties can diminish the ultimate result and thereby tarnish the justice applied. With all due respect, this Court must withdraw its opinion, address the merits of all procedural and substantive issues which are critical to administrative law and the parties, and issue a final decision based upon a clear showing of being vested with subject matter jurisdiction.

Sincerely,

/s/ Ron Beal Ron Beal Attorney at Law Bar Card No. 24005041 2530 Wooddale Circle Waco, TX 76710 254-366-4198 ron_beal@baylor.edu

CERTIFICATE OF COMPLIANCE I certify that this document was produced on a computer using Microsoft Word and contains 333 words, as determined by the computer’s software’s word count function, excluding the sections of the document listed in Texas Rules of Appellate Procedure 9.4(i)(1). CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document has been served on February 3, 2025, by e-file and/or electronic mail in accordance with the Texas Rules of Civil Procedure to the following: Appellant AFLOA

Brandon L. Starling Susan G. White 2003 N. Lamar Blvd., Suite 100 Austin, TX 78705 Appellee TDMV

Ted A. Ross P.O. Box 12548, Capitol Station Austin, TX 78711-2548

Sincerely,

Ron Beal Ron Beal Bar Card No: 24005041 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.

Ronald Beal on behalf of Ronald Beal Bar No. 24005041 ron_beal@baylor.edu Envelope ID: 96893901 Filing Code Description: Letter Filing Description: Letter Status as of 2/3/2025 10:18 AM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Brandon Starling 24047556 bstarling@wso-law.com 2/3/2025 10:14:02 AM SENT

Jeff Lutz jeff.lutz@oag.texas.gov 2/3/2025 10:14:02 AM SENT

Ted Ross ted.ross@oag.texas.gov 2/3/2025 10:14:02 AM SENT

Susan White swhite@wso-law.com 2/3/2025 10:14:02 AM SENT

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15th Court of Appeals February 3, 2025 P.O. Box 12547 Austin, TX 78711

Re: AFLOA, LLC v. TMVD Cause No: 15-24-00003-CV Amicus Letter Brief

Dear Honorable Justices of the 15th Court of Appeals:

I am not being compensated by anyone for the preparation, writing, or filing of this amicus letter brief.

I am solely concerned about the integrity of the Texas Administrative Law system and the fairness of administrative proceedings for our fellow Texas citizens and entities doing business in this State.

I have to admit that I have never been exposed to such conduct or, more appropriately, lack of conduct of the parties’ attorneys and this Court. A failure of all involved prejudices the rights of all parties to simply reach the merits of this cause consistent with the law and in a timely manner.

Sua sponte action or lack thereof of this Court should not be exercised to punish the tardy advocate. The key principles to be protected include consistent upholding of the rule of law as to jurisdiction, and the automatic exercise of sua sponte power so all advocates are treated in the same manner.

Finally, delay and additional costs to the parties can diminish the ultimate result and thereby tarnish the justice applied. With all due respect, this Court must withdraw its opinion, address the merits of all procedural and substantive issues which are critical to administrative law and the parties, and issue a final decision based upon a clear showing of being vested with subject matter jurisdiction.

Sincerely,

/s/ Ron Beal Ron Beal Attorney at Law Bar Card No. 24005041 2530 Wooddale Circle Waco, TX 76710 254-366-4198 ron_beal@baylor.edu

CERTIFICATE OF COMPLIANCE I certify that this document was produced on a computer using Microsoft Word and contains 333 words, as determined by the computer’s software’s word count function, excluding the sections of the document listed in Texas Rules of Appellate Procedure 9.4(i)(1). CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing document has been served on February 3, 2025, by e-file and/or electronic mail in accordance with the Texas Rules of Civil Procedure to the following: Appellant AFLOA

Brandon L. Starling Susan G. White 2003 N. Lamar Blvd., Suite 100 Austin, TX 78705 Appellee TDMV

Ted A. Ross P.O. Box 12548, Capitol Station Austin, TX 78711-2548

Sincerely,

Ron Beal Ron Beal Bar Card No: 24005041 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.

Ronald Beal on behalf of Ronald Beal Bar No. 24005041 ron_beal@baylor.edu Envelope ID: 96893901 Filing Code Description: Letter Filing Description: Letter Status as of 2/3/2025 10:18 AM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Brandon Starling 24047556 bstarling@wso-law.com 2/3/2025 10:14:02 AM SENT

Jeff Lutz jeff.lutz@oag.texas.gov 2/3/2025 10:14:02 AM SENT

Ted Ross ted.ross@oag.texas.gov 2/3/2025 10:14:02 AM SENT

Susan White swhite@wso-law.com 2/3/2025 10:14:02 AM SENT

AFLOA, LLC v. Texas Department of Motor Vehicles, (Tex. Ct. App. 2025).

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