Courtenay Paris, in Her Personal Capacity, and in Her Official Capacity as Chairperson on Behalf of Decriminalize Elgin, a Nonprofit, Unincorporated Political Action Committee v. the State of Texas; City of Elgin; Theresa Y. McShan, Mayor of Elgin; Sue Brashar, Mayor Pro Tem of Elgin; Joy Casnovsky, Arthur Gibson III, Yalecia Love, Chuck Swain, Matthew Callahan, Al Rodriguez, and Forest Lee Dennis, Members of the City Council of Elgin; Thomas Mattis, City Manager of Elgin; And Chris Noble, Chief of Police of Elgin; In Their Official Capacities

Opinion

ACCEPTED 15-24-00082 FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 2/12/2025 3:03 PM LAW OFFICE OF RICHARD GLADDEN CHRISTOPHER A. PRINE CLERK 1204 WEST UNIVERSITY DRIVE, SUITE 307 DENTON, TEXAS 76201 FILED IN 15th COURT OF APPEALS 940-323-9300 (Voice) AUSTIN, TEXAS 940-539-0093 (Fax) 2/12/2025 3:03:52 PM CHRISTOPHER A. PRINE February 12, 2025 Clerk

Christopher A. Prine, Clerk Fifteenth Court of Appeals William P. Clements Building 300 W. 15th Street, Suite 607 Austin, Texas 78701

Re: No. 15-24-00082, Paris v. State of Texas, in the Fifteenth Court of Appeals, Austin, Texas.

Dear Mr. Prine,

I would appreciate it if you would deliver this letter to the Honorable Presiding

Justice and Associate Justices of the Fifteenth Court of Appeals.

This morning, after observing the oral argument heard by the Fifteenth Court of

Appeals in State of Texas v. Harris County, No. 15-24-00120-CV (oral argument

heard Feb. 12, 2025), undersigned Counsel for Appellant Courtenay Paris in the

instant case discovered, for the first time, that the Appellees in State of Texas v.

Harris County, supra, have raised during oral argument (and have raised in their

brief on appeal) the question of whether the Attorney General of Texas may initiate

civil litigation in a state district court without authority that has been expressly

delegated by either Article IV, § 22 of the Texas Constitution (“Article IV, § 22”), or by any statute enacted by the Texas Legislature.1 This letter is submitted

primarily for the purpose of alerting the Court of Appeals to the fact that Appellant

Paris, on the present appeal, has previously raised the identical issue.2

Furthermore, Appellant Paris notes the Court of Appeals’ resolution of her issue

raised under Article IV, § 22 may render moot the other pending appeals also heard

by the Court at oral argument on February 12, 2025, i.e., State of Texas v. City of

Austin, No. 15-24-00077-CV (Tex. App. – Austin [15th Dist.]); and State of Texas

v. City of San Marcos, No. 15-24-00084-CV (Tex. App. – Austin [15th Dist.])

On the present appeal all appellate briefing by the opposing parties has

concluded, but the Court of Appeals has not yet determined whether Appellant

Paris’ appeal will be submitted with or without oral argument. In addition to what

has been stated above, Appellant Paris again requests her appeal in this case be set

for submission with oral argument so that she may address not only her issue

arising under Article IV, § 22, as described above, but also the other relatively

complex issues she has raised on her appeal.

1 Brief of Appellee Harris County, et al., No. 15-24-00120-CV, pages 16-30 (Tex. App. – Austin [15th Dist.]) (filed Jan. 14, 2025). 2 Appellant Paris’ Brief, pages 26-39 (No. 15-24-00082, filed Oct. 21, 2024); Appellant Paris’ Reply Brief, pages 9-11 (No. 15-24-00082, filed Jan. 9, 2025). 2 Respectfully submitted,

/s/Richard Gladden State Bar No. 07991330 1204 West University Dr., Ste. 307 Denton, Texas 76201940/323-9300 (Voice) 940/539-0093 (Fax) richscot1@hotmail.com (email) Attorney for Appellant Courtenay Paris

cc: All counsel of record (via ECF)

3 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.

Richard Gladden Bar No. 07991330 richscot1@hotmail.com Envelope ID: 97303850 Filing Code Description: Letter Filing Description: Appellant's Letter Brief Concerning Related Case Status as of 2/12/2025 3:07 PM CST

Associated Case Party: Courtenay Paris

Name BarNumber Email TimestampSubmitted Status

Richard Gladden richscot1@hotmail.com 2/12/2025 3:03:52 PM SENT

Terri Sparks terri.with.gladdenlaw@gmail.com 2/12/2025 3:03:52 PM SENT

Associated Case Party: The State of Texas

Name BarNumber Email TimestampSubmitted Status

Cory Scanlon 24104599 cory.scanlon@oag.texas.gov 2/12/2025 3:03:52 PM SENT

Associated Case Party: City of Elgin, Texas

Name BarNumber Email TimestampSubmitted Status

Gabrielle Smith 24093172 gsmith@lglawfirm.com 2/12/2025 3:03:52 PM SENT