Texas Court of Appeals, 15th District, 2025

Hays County, Texas, Ruben Becerra, Debbie Ingalsbe, Michelle Cohen, Morgan Hammer, and Walt Smith, in Their Official Capacities v. Leslie Carnes, Jim Camp, Cathy Ramsey, Gabrielle Moore, and Ken Paxton, Attorney General of Texas

Hays County, Texas, Ruben Becerra, Debbie Ingalsbe, Michelle Cohen, Morgan Hammer, and Walt Smith, in Their Official Capacities v. Leslie Carnes, Jim Camp, Cathy Ramsey, Gabrielle Moore, and Ken Paxton, Attorney General of Texas
Texas Court of Appeals, 15th District · Decided August 1, 2025
Hays County, Texas, Ruben Becerra, Debbie Ingalsbe, Michelle Cohen, Morgan Hammer, and Walt Smith, in Their Official Capacities v. Leslie Carnes, Jim Camp, Cathy Ramsey, Gabrielle Moore, and Ken Paxton, Attorney General of Texas

Opinion

ACCEPTED 15-25-00121-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 8/1/2025 8:26 AM ALESHIRELAW CHRISTOPHER A. PRINE CLERK A PROFESSIONAL CORPORATION 3605 SHADY VALLEY DR. FILED IN AUSTIN, TEXAS 78739 15th COURT OF APPEALS AUSTIN, TEXAS Bill Aleshire 8/1/2025 8:26:16 AM [email protected] CHRISTOPHER A. PRINE 750-5854 (call) 512 320-9156 (fax) Clerk

August 1, 2025 VIA FAX: (512) 463-1685 Third Court of Appeals Price Daniel Sr. Building West 14th Street, Room 101 Austin, Texas 78701 RE: Notice of Filing, Motion Challenging Jurisdiction of the 15th Court of Appeals, Case No. 15-25-00121-CV, Hays County et al v. Leslie Carnes et al., on Appeal from In re Hays County Cause, No. CAUSE NO. D-1-GN-25-002049, in the 126th Judicial District of Travis County,.

TO THE THIRD COURT OF APPEALS: On July 17, 2025, Hays County appealed a judgment from the above-styled case (The Hon. Catherine A. Mauzy, presiding) to the 15th Court of Appeals. On July 23, 2025, Appellees in Hays County v. Carnes filed what is titled a “Motion to Dismiss Pursuant to TRAP 42.3(a)” challenging the jurisdiction of the appeal in the 15th Court of Appeals.

Responses and Replies were filed thereafter. The Motion is pending.

It is possible the 15th Court of Appeals will consider the Motion to Dismiss (despite its title) to be a Motion to Transfer the case to the 3rd Court of Appeals. See Cohen v. Landry's Inc., 442 S.W.3d 818, 823 (Tex. App.—Houston [14th Dist.] 2014, pet. denied) (“The nature of a motion is determined by its substance, not its title or caption.”); see also Tex. R. Civ. P. 71 (“When a party has mistakenly designated any plea or pleading, the court, if justice so requires, shall treat the plea or pleading as if it had been properly designated.”)

In light of the Texas Supreme Court, on July 31, 2025, giving final adoption to TRAP Rule 27a, Appellees are providing the 3rd Court of Appeals notice, pursuant to TRAP Rule 27a(c)(3)(A), of the motion pending in the 15th Court of Appeals. Please let me know if the Court needs any additional information.

Respectfully submitted,

_____________________________ Bill Aleshire Texas Bar No. 24031810 AleshireLAW, P.C.

3605 Shady Valley Dr. Austin, Texas 78739 Cell: (512) 750-5854 Telephone: (512) 320-9155 Facsimile: (512) 320-9156 [email protected] Save Our Springs Alliance William G. Bunch State Bar No. 03342520 [email protected] Robert “Bobby” Levinski State Bar No. 24097993 [email protected] 4701 Westgate Blvd., D-401 Austin, TX 78745 Tel: 512-477-2320 Fax: 512-477-6410 ATTORNEYS FOR APPELLEES CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing instrument has been served upon all parties of record via e-filing on this 1st day of August, 2025.

MCGINNIS LOCHRIDGE LLP 1111 West Sixth Street, Building B, Suite 400 Austin, Texas 78703 512.495.6000 (telephone) 512.495.6093 (telecopier) [email protected] [email protected] [email protected] [email protected] Lynn Saarinen, Assistant Attorney General ATTORNEY GENERAL OF TEXAS FINANCIAL LITIGATION SECTION, GENERAL LITIGATION DIVISION MC-017 P. O. Box 12548 Austin, Texas 78711-2548 [email protected] Attorney General of Texas

_____________________________ Bill Aleshire Automated Certificate of eService This automated certificate of service was created by the efiling system.

The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.

William Aleshire on behalf of Bill Aleshire Bar No. 24031810 [email protected] Envelope ID: 103854972 Filing Code Description: Other Document Filing Description: Notice to the 3rd Court of Appeals of Jurisdiction Motion in 15th Court of Appeals Status as of 8/1/2025 9:11 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Ian M.Davis [email protected] 8/1/2025 8:26:16 AM SENT Michael Shaunessy [email protected] 8/1/2025 8:26:16 AM SENT Julie Denny [email protected] 8/1/2025 8:26:16 AM SENT Amy Botelho [email protected] 8/1/2025 8:26:16 AM SENT Austin Jones [email protected] 8/1/2025 8:26:16 AM SENT Bill Aleshire [email protected] 8/1/2025 8:26:16 AM SENT Bill Bunch [email protected] 8/1/2025 8:26:16 AM SENT Bobby Levinski [email protected] 8/1/2025 8:26:16 AM SENT William Gammon [email protected] 8/1/2025 8:26:16 AM SENT Lynn Saarinen [email protected] 8/1/2025 8:26:16 AM SENT

Case-law data current through December 31, 2025. Source: CourtListener bulk data.