Untitled Texas Attorney General Opinion: KP-0530

Texas Attorney General Reports·Decided September 17, 2026·No. KP-0530·Published

Opinion

September 17, 2026

The Honorable Joe Gonzales Bexar County Criminal District Attorney Paul Elizondo Tower 101 West Nueva San Antonio, Texas 78205

Opinion No. KP-0530

Re: House Bill 4490 and the confidentiality of next of kin information under Article 49.25 of the Texas Code of Criminal Procedure (RQ-0617-KP)

Dear Mr. Gonzales:

You ask five questions regarding a county medical examiner’s duty under the Public Information Act (“the PIA”) to release “information relating to the next of kin of a decedent” as provided in Article 49.25, subsection 11(d) of the Code of Criminal Procedure. 1 For context, you explain that the county medical examiner “plays a critical role in locating next of kin to ensure proper communication” about various topics concerning the decedent. Request Letter at 1. The Legislature recently amended the medical examiner’s duties in this regard via the passage of House Bill 4490, implementing new subsection 11(d), which excepts a decedent’s next-of-kin information from public disclosure under the PIA. 2 This amendment has resulted in a lack of clarity regarding the status of next-of-kin information, i.e., whether House Bill 4490 makes it confidential and thus prohibits disclosure. Id. at 3, 10. As a result, there is also “uncertainty for counties, medical examiners, and nonprofit donation organizations, with potential [disclosure] violations exposing county personnel and medical examiners to criminal penalties.” Id. at 10; see TEX. GOV’T CODE § 552.352 (specifying penalties for unlawful disclosure of confidential public information). Within this context you ask a series of questions seeking clarification about subsection 11(d) and its application, which we address in turn. Request Letter at 3.

Letter and Exhibits from Hon. Joe Gonzales, Bexar Cnty. Crim. Dist. Att’y, to Hon. Ken Paxton, Tex. Att’y 1

Gen. at 3 (Sept. 19, 2025), https://www.texasattorneygeneral.gov/sites/default/files/request-files/request/2025/ RQ0617KP.pdf (“Request Letter” and “Exhibits,” respectively).

Act of May 25, 2025, 89th Leg., R.S., ch. 459, § 1, 2025 Tex. Gen. Laws 1072, 1072 (codified at TEX. 2

CODE CRIM. PROC. art. 49.25, § 11(d)).

Article 49.25 excepts next-of-kin information from mandatory disclosure but does not make the information confidential.

The State’s policy is to make state information public. 3 TEX. GOV’T CODE § 552.001(a).

After all, “[s]unlight is said to be the best of disinfectants.” LOUIS D. BRANDEIS, OTHER PEOPLE’S MONEY, AND HOW THE BANKERS USE IT (1914), https://law.louisville.edu/lawlibrary/specialcollections /louis-d-brandeis-collection/writings-louis-d-brandeis/other-peoples-money-3. 4 The PIA is therefore “liberally construed in favor of granting a request for information,” TEX. GOV’T CODE § 552.001(b), and any exceptions to disclosure are narrowly construed to effectuate that purpose, Jackson v. State Off. of Admin. Hearings, 351 S.W.3d 290, 299 (Tex. 2011).

“[P]ublic information” is information that is “written, produced, collected, assembled, or maintained under a law or ordinance or in connection with the transaction of official business.” TEX. GOV’T CODE § 552.002(a). Such information falls within one of three categories under the PIA: “information required to be disclosed, information excepted from mandatory (but not voluntary) disclosure, and confidential information that is prohibited from disclosure and subject to criminal penalties.” Univ. of Tex. at Austin v. GateHouse Media Tex. Holdings II, Inc., 711 S.W.3d 655, 658 (Tex. 2024) (quoting Tex. Comptroller of Pub. Accts. v. Att’y Gen. of Tex., 354 S.W.3d 336, 360 (Tex. 2010) (Wainwright, J., dissenting in part and concurring in part)). Information such as a medical examiner’s “completed report, audit, evaluation, or investigation” is public information subject to required disclosure. TEX. GOV’T CODE § 552.022(a)(1). But not all public information may be accessed by the public under the PIA.

Certain information is excepted from disclosure if it is “considered to be confidential by law, either constitutional, statutory, or by judicial decision.” Id. § 552.101; accord id. §§ 552.022(a), .007(a). Confidential information is the most protected public information, as it is highly sensitive and thus must not be disclosed. See id. § 552.101; Tex. Comptroller, 354 S.W.3d at 360 (Wainwright, J., dissenting in part and concurring in part). Indeed, the PIA makes disclosure of such information a misdemeanor crime punishable by “fine, confinement, or both.” TEX. GOV’T CODE § 552.352(a), (b). Information excepted from mandatory disclosure, by contrast, may be voluntarily shared without triggering a criminal violation. See id. § 552.007(a) (permitting voluntary public disclosure unless disclosure is “expressly prohibited by law or the information is confidential under law”). The PIA’s text shows that the “Legislature intended the word ‘confidential’ to have a specific meaning in the PIA, separating highly sensitive information that

3 In this respect, the Legislature did not mince words. Subsection 552.001(a) states:

the fundamental philosophy of the American constitutional form of representative government that adheres to the principle that government is the servant and not the master of the people, it is the policy of this state that each person is entitled, unless otherwise expressly provided by law, at all times to complete information about the affairs of government and the official acts of public officials and employees.

TEX. GOV’T CODE § 552.001(a).

4 The statement and related discussion are located in Chapter V titled “What Publicity Can Do.”

is prohibited from disclosure (such as the home address of a peace officer) from sensitive information that is merely excepted from disclosure (such as information in a student record).” Tex. Comptroller, 354 S.W.3d at 360 (Wainwright, J., dissenting in part and concurring in part). With this background, we turn to your first question.

You ask whether subsection 11(d) excepts next-of-kin information “from mandatory disclosure,” thus “prohibit[ing] a county medical examiner from disclosing” this information to “tissue and corneal donation organizations” under the PIA. Request Letter at 3. Article 49.25 addresses a medical examiner’s duties related to “[i]nquests upon [d]ead [b]odies.” See TEX. CODE CRIM. PROC. arts. 49.01−.52 (addressing a medical examiner’s office and duties). Relevant here, section 11 addresses a decedent’s records that are in the medical examiner’s possession. Id. art. 49.25, § 11. Subsection 11(d), about which you inquire, provides that a decedent’s next-of-kin information is “excepted from required public disclosure in accordance with” the PIA, “but is subject to disclosure under subpoena or authority of other law.” Id. § 11(d). Thus, the main inquiry is whether the phrase “excepted from required public disclosure” bars disclosure by rendering the information confidential or only exempts it from mandatory disclosure. Request Letter at 3.

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