Cause No. 16-07-23803
WALLER COUNTY, TEXAS, § IN THE DISTRICT COURT OF
Plaintiff, §
§
ve § WALLER COUNTY, TEXAS
§
TERRY HOLCOMB SR., §
Defendant. § 506TH JUDICIAL DISTRICT
BRIEF OF AMICUS CURIAE KEN PAXTON, ATTORNEY GENERAL OF TEXAS
To THE HONORABLE JUDGE OF SAID Court:
Ken Paxton, Attorney General of Texas, files his brief as amicus curiae in
these proceedings.
The citizens shall have the right, in a peaceable manner, to assemble
together for their common good; and apply to those invested with the
powers of government for redress of grievances or other purposes, by
petition, address or remonstrance.
Tex. Const. art. 1 § 27. Section 411.209(d) of the Texas Government Code provides:
A citizen of this state or a person licensed to carry a concealed handgun
under this subchapter may file a complaint with the attorney general
that a state agency or political subdivision is in violation of Subsection
(a) if the citizen or person provides the agency or subdivision a written
notice that describes the violation and specific location of the sign
found to be in violation and the agency or subdivision does not cure the
violation before the end of the third business day after the date of
receiving the written notice. A complaint filed under this subsection
must include evidence of the violation and a copy of the written notice.
On May 23, 2016, Terry Holcomb sent the notice required by § 411.209(d) to
initiate the cure period for a violation of § 411.209; little more than a month later the