State of Texas v. City of San Antonio, Ron Niremberg, in His Official Capacity as Mayor of the City of San Antonio, and Erik Walsh, in His Official Capacity as City Manager of the City of San Antonio

Court of Appeals of Texas·Decided June 4, 2025·No. 15-25-00093-CV·Published

Opinion

ACCEPTED

15-25-00093-CV

FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS

6/4/2025 6:01 PM

No. 15-25-00093-CV CHRISTOPHER A. PRINE CLERK

In the Court of Appeals 15th COURT FILED IN OF APPEALS

AUSTIN, TEXAS

for the Fifteenth Judicial District6/4/2025 6:01:43 PM CHRISTOPHER A. PRINE

Austin, Texas Clerk

The State of Texas,

Appellant,

v.

City of San Antonio; Ron Nirenberg, in his official capacity as Mayor of the City of San Antonio; Erik Walsh, in his official capacity as City Manager of the City of San Antonio,

Appellees.

On Appeal from the

407th Judicial District Court, Bexar County

APPELLANT’S MOTION FOR TEMPORARY RELIEF In the aftermath of the U.S. Supreme Court’s decision in Dobbs v. Jackson

Women’s Health Organization, 597 U.S. 215 (2022), and the concomitant enforceability of Texas’s abortion laws, numerous Texas cities have attempted to avoid state

law by paying for women to travel to obtain elective abortions outside Texas’s bor- ders. San Antonio has recently joined the ranks of these cities, expressly stating and otherwise indicating its intent to use public money to pay for individuals’ travel for out-of-state abortions, as well as other “reproductive health” services to individuals.

But the Texas Constitution’s Gift Clauses create a “positive and absolute” prohibition on most gifts of public funds to private individuals. Bexar County v. Linden, 220

SW. 761, 762 (Tex. 1920); see, e.g., Tex. Const. art. III, § 52(a). San Antonio’s fund- ing program violates these provisions for multiple reasons.

And this program works irreparable harm to the State. “As a sovereign entity,

the State has an intrinsic right to . . . enforce its own laws,” State v. Naylor, 466 S.W.3d 783, 790 (Tex. 2015) (citing Printz v. United States, 521 U.S. 898, 912 n.5

(1997)), as well as an interest “in the maintenance and operation of its municipal

corporations in accordance with th[at] law,” State v. Hollins, 620 S.W.3d 400, 410 (Tex. 2020) (per curiam) (quoting Yett v. Cook, 281 S.W. 837, 842 (Tex. 1926)). Ab-

sent temporary relief here, Texas “would be impotent” to enforce its most funda- mental law, the state constitution, id., under this case’s circumstances. Per the City’s own representations, it intends to make unconstitutional payments this sum- mer—while the parties are briefing this appeal. None of the funds will be recoverable

once the City disburses them. Absent temporary relief, it is unlikely that any court will have a chance to determine whether those payouts are constitutional before the

City makes them—given recently enrolled legislation, the City will likely attempt to

make payments this summer.

Because it is highly unlikely that this Court will decide this appeal before the

date on which the City has expressly contemplated issuing its first payments, the

State requests an order preventing the City from issuing any payments under this funding program during the pendency of this appeal. After all, as the Texas Supreme

Court explained in another Gift Clause case, “this potential violation of the Texas Constitution cannot be remedied or undone if payments commence while the under- lying appeal proceeds.” In re State, No. 24-0325, 2024 WL 2983176, at *5 (Tex. June

14, 2024). Though the State does not file this motion as an emergency motion, see Tex. R. App. P. 10.3, it requests a ruling expeditiously so that it may seek further review if necessary.

Statement of Facts

I. Factual Background The City of San Antonio’s “Reproductive Justice Fund” (the Fund) provides

funding for certain “reproductive and sexual healthcare services.” App.0016, 0056.1 San Antonio does not itself furnish these services; instead, it disburses money from

the Fund to non-governmental organizations for them to use. See App.0056-57. Interested organizations apply for Fund money by submitting proposals explaining how

they plan to use it. See App.0032. The City distributes funds by entering into “agree-

ments” with recipient organizations. App.0016; see App.0056. The City has not suggested that it receives anything in exchange for these funds.

Recipients have used Fund monies for a variety of services that fall into three

different categories: upstream services, midstream services, and downstream services . App.0016; see also App.0056. In public-health parlance, “the term ‘upstream’

refers to policy approaches that have potential to affect large populations.”

App.0016, 0056. The term “downstream services,” on the other hand, means “policy approaches that have potential to affect . . . individual needs.” App.0016, 0056.

“Midstream” approaches “fall somewhere in between.” App.0016, 0056. In 2024,

1 The appendix attached to this motion contains Bates pagination. All citations to the appendix in this motion refer to that Bates pagination, not PDF pagination.

the City distributed approximately $500,000 from the Fund. App.0016-17, 0024, 0056. Those City dollars paid for things like “doula training, high school education on sexually transmitted infections (STIs), STI testing, contraception . . . , workshops

on healthy pregnancies and sexual and reproductive health, and wraparound prenatal care services including doula, acupuncture[,] and mental health services.”

App.0016-17, 0056. Examples of downstream services include “[t]ransportation to

abortion[s],” App.0023, and in the 2024 round of funding, “transportation to abortion . . . services was optional,” but “[n]one of the four awardees proposed abortion

transportation or navigation,” App.0026. The City finalized the 2024 funding agree- ments on November 21, 2024. App.0016, 0056.

The very next day, members of the San Antonio City Council sent a memo to the Community Health Committee (CHC), expressing their desire to “[p]rovide

downstream services that were not met through the already awarded $500,000.” App.0027. CHC proposed “provid[ing] an additional $100,000 to fund downstream

services” for “reproductive health”; these services, as the City noted, “could in-

clude travel out of State.” App.0017, 0056. On March 20, 2025, to “gauge interest” in this “new solicitation,” the City held a “virtual meeting” in which San Antonio’s

Metropolitan Health District (Metro Health), the City’s public-health agency,

App.0225, discussed CHC’s request, App.0017, 0056. The City invited to this meeting only the ten organizations that had previously applied for the 2024 round of fund-

ing. App.0027, 0029, 0056.

The day after that meeting, the City sent the organizations an interest form “ask-

ing whether they would be interested in pursuing a new funding opportunity specific

to downstream services.” App.0017, 0029, 0056. But while multiple types of “downstream services” exist, see App.0023, the interest form specifically high- lighted out-of-state travel for abortions, App.0017, 0029, 0057. Specifically, the form

asked the organizations “whether they would have interest in pursuing an additional funding opportunity specific to out of State travel” for abortions. App.0017, 0057;

see also App.0029. That was the only specific service that the interest form spot-

lighted (as opposed to the general category of “downstream services”). App.0017, 0029, 0057. Nine entities stated that they would like to receive funding; three of

those organizations “indicated interest in an additional funding opportunity limited to out-of-state travel for abortion”—that is, not including any other downstream ser- vices. App.0017, 0030, 0057. A fourth organization “indicated interest” in funding out-of-state travel for abortions “if the City were to provide legal protection for the

organization.” App.0017, 0030, 0057.

Metro Health asked the City Council to “authorize an expedited procurement

[process] to support downstream services for reproductive health care generally

and/or specific types of reproductive health care, which [could] include out-of-state travel.” App.0017; accord App.0057. Metro Health’s director reiterated that the

“[p]urpose” of this funding would be to “[p]rovide downstream services that were

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State of Texas v. City of San Antonio, Ron Niremberg, in His Official Capacity as Mayor of the City of San Antonio, and Erik Walsh, in His Official Capacity as City Manager of the City of San Antonio, (Tex. Ct. App. 2025).

State of Texas v. City of San Antonio, Ron Niremberg, in His Official Capacity as Mayor of the City of San Antonio, and Erik Walsh, in His Official Capacity as City Manager of the City of San Antonio (State of Texas v. City of San Antonio, Ron Niremberg, in His Official Capacity as Mayor of the City of San Antonio, and Erik Walsh, in His Official Capacity as City Manager of the City of San Antonio) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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