Qatar Foundation for Education, Science and Community Development, and Ken Paxton, Texas Attorney General v. Zachor Legal Institute

CourtCourt of Appeals of Texas
DecidedApril 15, 2021
Docket03-20-00129-CV
StatusPublished

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Qatar Foundation for Education, Science and Community Development, and Ken Paxton, Texas Attorney General v. Zachor Legal Institute, (Tex. Ct. App. 2021).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN

NO. 03-20-00129-CV

Qatar Foundation for Education, Science and Community Development and Ken Paxton, Texas Attorney General, Appellants

v.

Zachor Legal Institute, Appellee

FROM THE 200TH DISTRICT COURT OF TRAVIS COUNTY NO. D-1-GN-18-006240, THE HONORABLE KARIN CRUMP, JUDGE PRESIDING

OPINION

This is an appeal from the district court’s order sustaining Zachor Legal Institute’s

plea to the jurisdiction in Qatar Foundation’s suit under the Texas Public Information Act

(TPIA). Qatar Foundation filed suit against the Attorney General to prevent the disclosure of

information in response to a request for public information that Zachor Legal Institute had

submitted to Texas A&M University. Based on our conclusion that the TPIA waives sovereign

immunity for Qatar Foundation’s suit, we reverse the district court’s order and remand the case

for further proceedings.

BACKGROUND

Qatar Foundation is a private, non-profit organization headquartered in Doha,

Qatar. Its self-described mission is “to lead human, social, and economic development in Qatar through investment in education, science, and research.” As part of that mission, Qatar

Foundation partners with universities around the world, including Texas A&M, to open and

operate branch campuses at its “Education City” in Qatar.

In May 2018, Zachor Legal Institute submitted a request for public information to

Texas A&M for a “summary of all amounts of funding or donations received by or on behalf of

[Texas A&M] from the government of Qatar and/or agencies or subdivision of the government

of Qatar between January 1, 2013 and May 22, 2018.”1 See Tex. Gov’t Code § 552.021

(requiring that public information be made available to public). Texas A&M, which did not

notify Qatar Foundation about the request, asked the Attorney General for a decision about

whether it had to release information that “identifies donors to the university.” See id.

§§ 552.1235(a) (excepting from disclosure information disclosing the identity of person, other

than governmental body, making a gift, grant, or donation of money to institution of higher

learning), .301 (directing governmental body seeking to withhold information to request

Attorney General opinion), .305(d) (directing governmental body to make good-faith effort to

notify third party of request involving privacy or property interests). The Attorney General’s

subsequent letter ruling, issued in August 2018, concluded that Texas A&M “must withhold the

donors’ identifying information” under section 552.1235 but directed it to “release the remaining

information,” which included information related to contractual payments Qatar Foundation had

made to Texas A&M. See Tex. Att’y Gen. OR2018-20240. Texas A&M did not challenge the

letter ruling.

1 The request characterized Qatar Foundation as an agency or subdivision of the Qatari government. Qatar Foundation disputes this characterization. 2 Qatar Foundation, which maintains that it was not aware of Zachor Legal

Institute’s request until two months after the Attorney General’s letter ruling issued, filed the

underlying suit for declaratory judgment against the Attorney General in October 2018. In its

suit, Qatar Foundation asserted and sought declarations that information responsive to the

request is protected from disclosure under the TPIA because the information constitutes trade

secrets and confidential commercial or financial information and because it reveals the amount

of the grant or donation and the identity of the donor. See id. §§ 552.110(a)–(b) (excepting trade

secrets and certain commercial and financial information from disclosure), .1235(a). Qatar

Foundation relied on section 552.325 as the asserted basis for jurisdiction over its suit. See id.

§ 552.325(a) (“A governmental body, officer for public information, or other person or entity

that files a suit seeking to withhold information from a requestor may not file suit against the

person requesting the information.”); Boeing Co. v. Paxton, 466 S.W.3d 831, 833, 839 (Tex.

2015) (recognizing that section 552.325 provides judicial remedy to third party seeking to

withhold requested information). Zachor Legal Institute intervened in the suit. See Tex. Gov’t

Code § 552.325(a).

Soon after Qatar Foundation filed its suit, Zachor Legal Institute submitted a

second TPIA request, this time asking for “[a]ll correspondence and communications between

[Texas A&M] and third parties relating to [the first request for information]” and “[a]ll

communications relating to [Texas A&M] funding, programs and activities between [Texas

A&M] and the parties listed in [the first request for information] between 2013 and the current

date.” Texas A&M notified Qatar Foundation and asked the Attorney General for an opinion

about whether the requested information is excepted from disclosure under TPIA sections

552.104, 552.110, and 552.1235. See id. §§ 552.104 (excepting from disclosure information

3 related to competition or bidding), .110, .1235. Qatar Foundation sent the Attorney General a

detailed letter explaining why its negotiations and agreements with partner universities, including

Texas A&M, and information regarding the amounts and types of funding are exempt from

disclosure under sections 552.104, 552.110, and 552.1235. See id. § 552.305(b) (allowing

person whose privacy or property interests are involved in TPIA request to submit to Attorney

General reasons why the information should be withheld or released).

In a second letter ruling, the Attorney General concluded that Qatar Foundation

had established that release of the requested information “would give an advantage to a

competitor or bidder,” see id. § 552.104(a), and directed Texas A&M to withhold the

information. See Tex. Att’y Gen. OR2019-01288. The Attorney General also noted that because

some of the information responsive to Zachor Legal Institute’s request may be affected by his

first letter ruling, he would defer to the trial court to make its own independent determination

regarding disclosure: “[The Attorney General] will allow the trial court to resolve the issue of

whether the information that is the subject of the pending litigation must be released to the

public.” Id.

Zachor Legal Institute filed a plea to the jurisdiction in the underlying case,

arguing that the district court lacks jurisdiction over Qatar Foundation’s suit because “[n]o

provision of the TPIA authorizes a third party that asserts privacy or property interests to file a

lawsuit to challenge a decision of the Attorney General.” Both Qatar Foundation and the

Attorney General filed briefs opposing Zachor Legal Institute’s jurisdictional argument, but the

district court sustained Zachor Legal Institute’s plea to the jurisdiction and dismissed Qatar

Foundation’s case. Qatar Foundation appeals.

4 ANALYSIS

In a single issue, Qatar Foundation asserts, and the Attorney General agrees, that

the district court erred in sustaining Zachor Legal Institute’s plea to the jurisdiction because the

district court has jurisdiction over an action brought against the Attorney General by a third party

who seeks to withhold protected information from disclosure under the TPIA. Zachor Legal

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Qatar Foundation for Education, Science and Community Development, and Ken Paxton, Texas Attorney General v. Zachor Legal Institute, Counsel Stack Legal Research, https://law.counselstack.com/opinion/qatar-foundation-for-education-science-and-community-development-and-ken-texapp-2021.