Keith Shannon v. Texas Workforce Commission
This text of Keith Shannon v. Texas Workforce Commission (Keith Shannon v. Texas Workforce Commission) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.
Opinion
Cause NO, 2025-DCV — 0955 Appeal No. 15-25-00129-CV
DEC 31 2025
CHRISTOPHER A. PRINE
Keith Shannon, g Inthe + a § Plaintiff, th s 154 m § Texas Workforce Commission, § § COURT OF APPEALS Defendant, § § AUSTIN, TEXAS
Motion to Extend Time to File
Plaintiff’s Motion to Challenge the Constitutionality of Statute
The Plaintiff, Appellant, Pro Se, Mr. Shannon seeks to extend his time to file his Motion to Challenge the Constitutionality of a Statute pursuant to the Texas Rules Appellate Procedure Rule 10.5(b). The following facts pertain to the
request:
Mr. Shannon’s Challenge to Constitutionality of State Statute was due to be
filed by August 15, 2025.
The Mr. Shannon made several attempts before and after the deadline to
download the preformatted document from the Court’s website, but it would not “a
website downloaded without issue.
Mr. Shannon filed, “Notice: Challenge to Constitutionality of Statute,” to alert the Court to the issue. It was filed on the deadline, August 15, 2025, in the 346"
District Court under the belief it would reach the 15th Court of Appeals.
On December 4, 2025 Mr. Shannon was able to download the Court’s preformatted document which he filled out and filed with the 346th District Court, within his “Plaintiff's Amended Notice: Challenge to Constitutionality of
Statute”, under the belief that his filings were reaching the 15th Court of Appeals.
About December 15, 2025 Mr. Shannon received and email from the clerk of 15th Court of Appeals, dated December 9, 2025, that suggested his filings were not reaching the Court. Mr. Shannon seeks to file his documents with the Court
post haste, so files this motion to explain the situation. No Prior Extensions Requested
The Appellant, Keith Shannon, has not made any prior requests for an extension of time to file his Appellant Brief and the Appeals Court has not granted
any such request to him.
Amended Motion to Challenge the Constitutionality of a Statute to December 19,
2025 based on the facts available to the Court and those given in this motion.
Certificate of Conference
As required by Texas Rule of Appellate Procedure 10.1(a)(5), [| certify that | have made a reasonable attempt to confer, with the counsel for the Texas Workforce Commission—which is listed below—about the merits of this motion with the
following result:
On December 18, 2025 | called Peter Berquist who could not be reached at
the number he provided to me. The number, (512) 478-4013 was
disconnected.
The motion is presumed to be opposed.
KEITH SHANNO 2825 Grant Ave. Apt #3 El Paso TX. 79930 kshanvon@aol.com (915) 202-6382
Date
Certificate of Service
|, Keith Shannon, Plaintiff Pro se, hereby certify that | have served a true and correct copy of this, Motion for Extension of Time to File Plaintiff's Appellant Brief, upon its General Counsel, at the email or address listed below, on or about the 19"" day of December, 2025.
Peter Berquist
General Counsel
Texas Workforce Commission
101 East 15" Street, Suite 608 peter.berquist@oag.texas.gov Austin, Texas 78778
(512) 478-4013
KEITH SHANNON: Plaintiff Pro Se
WduUoat INO, 2ULO-LAL VOU
Appeal No. 15-25-00129-CV
Keith Shannon, 8 Inthe vos § Plaintiff, § 15/H v. § Texas Workforce Commission, § § COURT OF APPEALS Defendant, §
§ AUSTIN, TEXAS
Amended Notice: Challenge to Constitutionality of Statute
The Plaintiff, Appellant, Keith Shannon intends to challenge the constitutionality of Tex. Lab. Code 212.201, including the manner it was applied to this case by the trial court.
The form provided for such challenges available through the Texas Judicial Branch website would not download, so the original “Notice: Challenge to Constitutionality of Statute” was filed on August 15, 2025 to meet the deadline.
The Plaintiff has since acquired the form; it is page two this amended notice.
RUMSCILUI at yy Ul at SEALE Oa tEL, 2 PAP OlO Ada TEE DO area WYELEE tli Ga bid WTINE LEI Lethon ES pending as required by Section 402.010 (a-L), Texas Government Code.
45-25-00129-CV 15th Court of Appeals Cause Number (known): 2025DCV0935 = Court apknown): 346th District Court
Styled: Keith Shannon v. Texas Workforce Commission
(e.2., John Smith v. All American insurance Co.; in re Mary Ann Jones; In the Matter of the Estate of George Jackson}
Contact information. for party* challenging 1 the: constitutionality of a State statute, e CU party | is. not: @ person, pre rovide oe contact infor mation for party, party's representative or attorney, }
Name: Keith Shannon Telephone: 91 52026382 Address: 2825 Grant Ave. Apt#3 Fax:
City/State/Zip: El Paso Texas 79930 State Bar No. (if applicable): Email: kshanvon@aol.com
Person completing this form is: {_] Attorney for Party [] Unrepresented Party [1] Other:
identify the type of pleading you haye filed challenging the constitutionality of a state statute,
[] Petition [J Answer [3 Motion (Specify type): [4] Other: Appellant Brief
Is the ‘Attorney General of the State. of Texas a A part Pte
ee
[¥] Yes [[] No
List the state statute(s) being challenged in your pleading and provide a a summar KY of the basis for your. challenge. (Additional pages may be attached if necessary.) . os SS - nts
Tex. Lab Code Saction 212.XX has a 28 day deadiine for a plaintiff to seek judicail review that is strictly interpreted by the courts. This makes it unconstitutional in the interest of equality. First not everyone gets the same nor even a minimum allotment of time to prepare their petition, due to the Commission's ability fo hold onto its decisions as long as it wants before _ sending them to the Plaintiff. The Commission currently has the option to hold onto its decision for the entire 28 days then have every Plaintiff's claim thrown out for a lack of jurisdiction, Second not all cases are simple, some are quite complex. If the Plaintiff must proceed pro se the less than 28 days one has to prepare the petition amounts to a deprivation of one’s Constitutionally guaranteed access to the courts, which is exacerbated by the strict inflexible 28 day deadline.
EITH SHANNON 2825 Grant Ave. Apt #3 El Paso TX. 79930 kshanvon@aol.com (915) 202-6382
|, Keith Shannon, Plaintiff Pro se, hereby certify that | have served a true and correct copy of this, Notice: Challenge to Constitutionality of Statute, upon its General Counsel, at the email or address listed below, on or about the 19th day of December, 2025.
101 East 15" Street, Suite 608 peter. berquist@oag.texas.gov Austin, Texas 78778
KEITH SHANNON: Platt
|
Keith Shannon
— Retait
2 Iii
78711 RDC 99
2825 Grant Ave. Apt. 3 on CEGEIVED IN 1 RT OF APPEAL: Ej Paso, Texas 79930 AUSTIN, TEXAS DEC 31 2025 CHRISTOPHER A. PRINE CLERK FILED IN 15th COURT OF APPEALS AUSTIN, TEXAS DEC 31 2025 CHRISTOPHER A. PRINE CLERK
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Fifteenth Court of Appeals P.O. Box 12852 Austin, Texas 78711
U. S. POSTAGE PAID | FCM LG ENV EL PASO, TX 79903 DEC 19, 2025
$1.90
$2324E502179.33
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