Hays County, Texas, Ruben Becerra, Debbie Ingalsbe, Michelle Cohen, Morgan Hammer, and Walt Smith, in Their Official Capacities v. Leslie Carnes, Jim Camp, Cathy Ramsey, Gabrielle Moore, and Ken Paxton, Attorney General of Texas

Court of Appeals of Texas·Decided August 4, 2025·No. 15-25-00121-CV·Published

Opinion

ACCEPTED

15-25-00121-CV

FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS

8/4/2025 5:31 PM

No. 15-25-00121-CV CHRISTOPHER A. PRINE CLERK

FILED IN

In the Court of Appeals, 15th District of 15th TexasCOURT OF APPEALS

AUSTIN, TEXAS

______________________________ 8/4/2025 5:31:01 PM CHRISTOPHER A. PRINE

HAYS COUNTY, TEXAS, RUBEN BECERRA, DEBBIE INGALSBE, Clerk

MICHELLE COHEN, MORGAN HAMMER, and WALT SMITH, Appellants,

v.

LESLIE CARNES, JIM CAMP, CATHY RAMSEY, GABRIELLE MOORE, and KEN PAXTON, ATTORNEY GENERAL OF TEXAS Appellees.

On Appeal from the 126th Judicial District Court, Travis County, Texas

KEN PAXTON, ATTORNEY GENERAL OF TEXAS’, RESPONSE TO APPELLEES’ MOTION TO DISMISS

INTRODUCTION

The Legislature has charged the Attorney General with reviewing and approving the issuance of public securities in the State of Texas. Chapter 1202 of the Government Code requires governmental entities, and nonprofit corporations created to act on their behalf, to submit public securities, including bonds, along with the authorizing proceedings (known as "bond transcripts") to the Attorney General for review and approval before the bonds can be issued. See Tex. Gov't Code § 1202.003. As part of this process, the Attorney General must review the transcript and the bonds and determine whether the bonds have been authorized to be issued in compliance with state law. Id. In this case, for the tax bonds to be lawfully issued, an election must be lawfully held. Because taxpayers challenged the validity of the election through an election contest, the issuer brought this expedited declaratory judgment action for the trial court to determine the validity of the election and the bonds and served the Attorney General as a necessary party. The Attorney General examined the petition and filed his answer raising appropriate defenses, as required by section 1205.063. Therefore, this is an action against the Attorney General and jurisdiction is proper before the 15th Court of Appeals. Chapter 1205 Bond Validation Lawsuits Appellants filed its lawsuit pursuant to Chapter 1205 of the Texas Government Code, known as the Expedited Declaratory Judgment Act (“EDJA”). When the Texas Legislature established this expedited legal process, it enacted a law requiring that the Attorney General be a mandatory party to such actions. Section 1205.041 directs that upon the filing of a Chapter 1205 petition, the court shall issue an order directed

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to all persons who have an interest in the lawsuit. The order must advise those persons and the Attorney General of their right to “(1) appear for trial at 10 a.m. on the first Monday after the 20th day after the date of the order; and (2) show cause why the petition should not be granted and the public securities or the public security authorization validated and confirmed.” Tex. Gov't Code Ann. § 1205.041(b). The order “shall be served” on the Attorney General. Tex. Gov't Code Ann. § 1205.042(a) (emphasis added). In fact, the Attorney General is the only person who is personally served with the order and a copy of the petition. Id. Otherwise, notice is provided by publishing a “substantial copy” of the order in a newspaper of general circulation in Travis County, the county of the issuer’s principal office, and each county in which the issuer has territory. Tex. Gov't Code Ann. § 1205.043(a).

As a party, Tex. Gov't Code Ann. § 1205.063(a) mandates that “[t]he attorney general shall examine a petition”… “and shall raise appropriate defenses” if there are potential legal deficiencies with the petition or the bonds at issue. Tex. Gov't Code Ann. § 1205.063(a). “If the attorney general does not question the validity of the public securities, the public security authorization, or an expenditure of money relating to the public securities or the security or provisions for the payment of the public

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securities, the attorney general may: (1) state that belief, and (2) on a finding by the court to that effect, be dismissed as a party.” Tex. Gov't Code Ann. § 1205.063(b) (emphasis added).

While it is unquestioned whether the Attorney General must be a party to a 1205 lawsuit, the real question as to whether the Fifteenth Court of Appeals has jurisdiction is whether the lawsuit is “against” the Attorney General.

This EDJA Action is “Against” the Attorney General, who participated and raised appropriate defenses in this case.

The Petition filed by Appellants is “against” the Attorney General and Appellants correctly state that the Attorney General is in a posture adverse to Hays County. Appellants’ Response to Appellees’ Motion to Dismiss, p.11. Appellees are incorrect when they state the Attorney General’s only role is “to provide information and legal analysis” to the trial court. Appellees’ Motion to Dismiss Under TRAP 42.3(A), p.4. The Attorney General did much more than that in this case with both the Texas Open Meetings Act (“TOMA”) issues and the EDJA issues.

As previously stated, the Attorney General “shall examine a petition”… “and shall raise appropriate defenses”. Tex. Gov't Code § 1205.063(a). Those are not mere suggestions. Section 311.016(2) of the

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Government Code instructs that “[s]hall imposes a duty.”

In line with the mandates in § 1205.063(a), the Attorney General raised numerous defenses to the mandatory allegations that must be included in an EDJA petition under section 1205.024 of the Government Code.

The Attorney General found Appellants’ assertion that it has the authority to issue the Bonds to be defective because some of the road projects exceeded Hays County’s authority. See, AG’s Answer, attached, p.2, ¶1. Because there were potential defects in providing notice of the meeting to call the bond election, the Attorney General raised those defects in response to Appellants’ claim that the Notices were sufficient and gave proper notice of the election to its constituents. AG’s Answer, p.2, ¶1. Appellants’ Reimbursement Resolution was found to be defective because Hays County does not have authority to unilaterally construct roads outside of its boundaries, nor has it secured the cooperation of the parties necessary for such projects. AG’s Answer, p.2, ¶2, p.3 ¶4. Furthermore, constructing only the portion within its boundaries would violate its contract with the voters. AG’s Answer, p.2, ¶2.

Appellants failed to include “the interest rate or rates or the proposed maximum interest rate of the public securities” as required by

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section 1205.024(6). The Attorney General raised this defect since only an estimated maximum net effective interest rate was given. AG’s Answer, p.3, ¶3.

The Attorney General also found some declarations requested by Hays County to be defective for the same reasons. AG’s Answer, p.3, ¶5. Finally, Hays County’s request that each public security authorization with respect to Proposition A is legal and valid was found to be defective because it did not identify the public security authorizations. AG’s Answer, p.3, ¶6.

In his Answer, the Attorney General’s explanation, pursuant to Tex. Gov’t Code § 1205.063(a)(2), as to why “the public securities are, or the public security authorization or an expenditure of money relating to the public securities is or will be invalid or unauthorized”, was over two pages long. AG’s Answer, pp.3-6.

In his fourteen-page trial brief, the Attorney General devoted six pages to the Texas Open Meetings Act issues and two and one-half pages to the bond issues. And, at the trial, the Attorney General participated vigorously and defended his positions.

Appellees rely heavily on Justice Young’s concurring opinion in Six Bros. Concrete Pumping, LLC v. Tex. Workforce Comm’n, No. 23-0711,

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Hays County, Texas, Ruben Becerra, Debbie Ingalsbe, Michelle Cohen, Morgan Hammer, and Walt Smith, in Their Official Capacities v. Leslie Carnes, Jim Camp, Cathy Ramsey, Gabrielle Moore, and Ken Paxton, Attorney General of Texas, (Tex. Ct. App. 2025).

Hays County, Texas, Ruben Becerra, Debbie Ingalsbe, Michelle Cohen, Morgan Hammer, and Walt Smith, in Their Official Capacities v. Leslie Carnes, Jim Camp, Cathy Ramsey, Gabrielle Moore, and Ken Paxton, Attorney General of Texas (Hays County, Texas, Ruben Becerra, Debbie Ingalsbe, Michelle Cohen, Morgan Hammer, and Walt Smith, in Their Official Capacities v. Leslie Carnes, Jim Camp, Cathy Ramsey, Gabrielle Moore, and Ken Paxton, Attorney General of Texas) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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