Untitled Texas Attorney General Opinion: KP-0524

Texas Attorney General Reports·Decided August 20, 2026·No. KP-0524·Published

Opinion

KE PAXTO

ATTORNEY GENERAL OF TEXA

August 20, 2026

Mr. Dwayne Gott, CPA Liberty County Auditor 310 Main Street Liberty, Texas 77575

Opinion No. KP-0524

Re: Authority of a county commissioners court to adopt a policy prohibiting use of county- owned law enforcement vehicles in the performance of private security jobs outside the county (RQ-0518-KP)

Dear Mr. Gott:

You ask three related questions about the use of county-owned law enforcement vehicles. 1 You explain that “[i]t is currently the policy of the Sheriff’s Department and a Constable to allow county-owned law enforcement vehicles to be used by their deputies for travel to and in the performance of [private security] jobs outside of Liberty County.” Request Letter at 2. Your first two questions pertain to where the authority to set a policy addressing such use resides. Id. at 1. Specifically, you ask whether the commissioners court may adopt a policy prohibiting this use of county vehicles and whether a sheriff’s or constable’s office may adopt a policy permitting such use. Id. In your final question, you ask whether a policy allowing county-owned vehicles to be used for private security work in another county would violate article III, subsection 52(a) of the Texas Constitution. Id. Because constitutionality may shape our analysis of your other questions, we examine that issue first.

A policy allowing county-owned vehicles to be used for private security jobs outside the county satisfies article III, subsection 52(a) only if the use is not gratuitous, a legitimate public purpose is the policy’s predominant objective, and the county retains control over the vehicles.

Article III, subsection 52(a) of the Texas Constitution is one of several “Gift Clauses” that originally “arose from skepticism about entanglement between public funds and private

1 See Letter from Dwayne Gott, CPA, Liberty Cnty. Auditor, to Honorable Ken Paxton, Tex. Att’y Gen. at 1 (Oct. 23, 2023), https://www.texasattorneygeneral.gov/sites/default/files/request-files/request/2023/RQ0518KP.pdf (“Request Letter”).

enterprise.” 2 JPMorgan Chase Bank, N.A. v. City of Corsicana, No. 24-0102, 2026 WL 1261549, at *1 (Tex. May 8, 2026). These provisions were “intended to prevent the application of public funds to private purposes; in other words, to prevent the gratuitous grant of such funds to any individual, corporation, or purpose whatsoever.” Byrd v. City of Dallas, 6 S.W.2d 738, 740 (Tex. [Comm’n Op.] 1928). Relevant here, subsection 52(a) prohibits the Legislature from “authoriz[ing] any county . . . to lend its credit or to grant public money or thing of value” to a private party. 3 TEX. CONST. art. III, § 52(a). This prohibition reaches beyond the expenditure of funds to encompass the use of other valuable public resources, including a commissioners court permitting “the use of county labor, materials or equipment for other than public use.” Godley v. Duval Cnty., 361 S.W.2d 629, 630 (Tex. Civ. App.—San Antonio 1962, no writ); see also Ex parte Conger, 357 S.W.2d 740, 742 (Tex. 1962) (holding that a county commissioner’s use of county equipment “on privately owned property to furnish parking facilities for the use of members in attending services at their church is not for a public use or purpose”).

In evaluating compliance with subsection 52(a), the Texas Supreme Court has distilled the “various cumbersome ‘tests’ and ‘requirements’ and ‘prongs’ into three principles” as follows:

A challenged expenditure satisfies [subsection] 52(a)’s Gift Clause when (1) the expenditure is not gratuitous but instead brings a public benefit; (2) the predominant objective is to accomplish a legitimate public purpose, not to provide a benefit to a private party; and (3) the government retains control over the funds to ensure that the public purpose is in fact accomplished.

Borgelt, 692 S.W.3d at 301 (emphasis omitted). These principles primarily stem from the Court’s Texas Municipal League decision. Id. at 300 (summarizing Tex. Mun. League Intergov’tl Risk Pool v. Tex. Workers’ Comp. Comm’n, 74 S.W.3d 377 (Tex. 2002)). In restating that case’s legal framework, the Court in Borgelt was clear that it “aim[ed] only to eliminate the complexity of how Texas Municipal League articulated the test” while expressly “disclaim[ing] any substantive deviation from its analysis or from the precedents that it cited.” Id. at 301 n.15. Accordingly, we apply these principles, along with court decisions and legal opinions interpreting Texas Municipal League, to your question regarding subsection 52(a).

Turning to the first principle, a political subdivision’s grant of a valuable public resource, such as the private use of a county vehicle, “is not ‘gratuitous’ if the political subdivision receives return consideration.” Tex. Mun. League, 74 S.W.3d at 383. This requires receipt of “only sufficient—not equal—return consideration” in exchange for allowing such use. Id. at 384. A

2 The Texas Supreme Court has noted that “our Constitution also contains a Gift Clause specifically relevant to local governments.” Borgelt v. Austin Firefighters Ass’n, IAFF Loc. 975, 692 S.W.3d 288, 299 n.9 (Tex. 2024) (citing TEX. CONST. art. XI, § 3). However, the Court in Borgelt “express[ed] no opinion about whether this provision has any meaning that is materially distinct from [subsection] 52(a) or the other Gift Clauses that the parties cite.” Id. Because your request similarly makes no reference to article XI, section 3, we too analyze your inquiry solely under subsection 52(a).

3 We note that the phrase “thing of value” is unique to subsection 52(a) and does not appear in the Constitution’s other Gift Clause provisions. See, e.g., TEX. CONST. art. III, §§ 50, 51; id. art. XI, § 3; id. art. XVI § 6(a).

vehicle use policy would fall short of this requirement if it authorized the use of county-owned vehicles either “‘for uses not related to . . . governmental duties,’ or for no particular use at all, i.e., ‘as a gratuity.’” See Borgelt, 692 S.W.3d at 302 n.16 (citation omitted). But your request concerns a policy that permits deputies to use county law enforcement vehicles for a specific purpose— “travel to and in the performance of [private security] jobs outside of Liberty County.” Request Letter at 2. You do not identify any governmental duties purportedly served by allowing the use of county vehicles in this manner. See generally id. However, some out-of-county uses may bear a sufficiently close relationship to official duties to satisfy this first principle.

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