U.S. Const. Amend. I Sunday Edition — March 15, 2026 Ides of March

Amendment
I

Two Texas statutes. One constitutional clause. Opposite outcomes — resolved within the same week.

Enforced — 5th Circuit Woodlands Pride, Inc. v. Paxton · SB 12 No. 23-50636 · Injunction Vacated · Takes Effect March 18 ▲ Drag Ban Active
Enjoined — W.D. Texas Turtle Island Foods v. Shuford · SB 664 No. 1:23-cv-00492 · Facially Enjoined · 96% consumers not misled ▼ Labeling Law Struck
Scroll
Enforced
First Amendment · Fifth Circuit

Texas Drag Ban
Takes Effect March 18

Woodlands Pride, Inc. v. Paxton No. 23-50636 5th Cir. — Feb. 25, 2026 Tex. S.B. 12 (88th Leg., 2023)

After more than two years under a federal injunction, Texas Senate Bill 12 — the state's law prohibiting "sexually oriented" performances in the presence of minors — is now enforceable. On February 25, 2026, the Fifth Circuit vacated the permanent injunction that had blocked the law, declined to rule the statute facially unconstitutional, and remanded to the district court for further constitutional analysis under United States v. Rahimi and other recent Supreme Court precedents.

The Fifth Circuit's panel found that only one of five plaintiffs challenging the law — The Woodlands Pride organization — had standing to challenge it. The others lacked sufficient connection to the regulated conduct. That standing ruling has immediate practical consequences: other performers and organizations who believe they are affected by SB 12 will need to establish their own standing to bring constitutional challenges.

Law Takes Effect
March 18, 2026
3 days from this edition ·
District court litigation continues
$10,000 Max Civil Fine
Business Owners
Class A Misdemeanor
Performers
1 Yr Max Jail
Potential

Practitioners advising venues, event organizers, and performers should note that the law's language remains ambiguous — the Fifth Circuit acknowledged the statute's broad scope without resolving whether specific performances are covered. Until the district court issues further guidance on remand, compliance requires conservative interpretation of what constitutes a "sexually oriented performance" under Tex. Bus. & Com. Code § 131. Family-friendly and all-ages drag performances remain expressly legal; the contested edge cases will be resolved in further litigation.

The Daily Texan — Fifth Circuit Lifts SB 12 Injunction ACLU of Texas — Case Page
First Amendment · W.D. Texas · Same Week

Same Clause,
Opposite Verdict

In a ruling that creates a striking doctrinal contrast with the SB 12 decision, the U.S. District Court for the Western District of Texas enjoined Senate Bill 664 — the state's "fake meat" labeling law — finding it violates the First Amendment's protection of commercial speech. The same constitutional provision that failed to block SB 12 succeeded in blocking SB 664.

SB 12 — Drag Shows
Tex. S.B. 12 (2023)
"Sexually Oriented Performances"
Law prohibits "sexually oriented" performances in the presence of minors. Fifth Circuit vacated the injunction. Court found standing limited, remanded for further constitutional analysis. Enforcement proceeds pending district court review.
▲ Enforced — Injunction Vacated
First Amendment
SB 664 — Plant-Based Labels
Tex. S.B. 664 (2023)
"Fake Meat" Mandatory Labeling
Law required plant-based products to bear labels like "analogue," "meatless," or "plant-based" next to product names. Court found labels not misleading — 96% of Texans correctly identified products without the mandated terms. Mandatory label increased consumer confusion.
▼ Enjoined — First Amendment Violation

The case, Turtle Island Foods, Inc. v. Shuford, challenged SB 664 on First Amendment, federal preemption, Dormant Commerce Clause, and due process grounds. The court's First Amendment analysis rested on the Central Hudson commercial speech framework — finding that the state could not demonstrate its interest in preventing consumer confusion was substantial when the evidence showed consumers were not confused. A survey showed 96% of Texans correctly identified Tofurky and other plant-based products as meatless without any state-mandated labels.

For food and agriculture lawyers: the decision limits Texas's power to compel specific commercial speech when the asserted interest — here, consumer clarity — is contradicted by empirical evidence. State regulators seeking to mandate product labeling will now need to demonstrate actual consumer confusion with data, not assumptions.

Texas Agriculture Law Blog — SB 664 First Amendment Ruling
Texas Supreme Court · Certified Question

Is Your LLC Interest
Exempt in Bankruptcy?

On February 11, 2026, the U.S. Court of Appeals for the Fifth Circuit certified a question of first impression to the Texas Supreme Court: does a membership interest in a Texas LLC constitute exempt property in a federal bankruptcy proceeding? The Texas Supreme Court accepted the certified question on March 6, 2026.

Certified Question · No. 25-0195 Accepted — Mar. 6, 2026
"Is an LLC membership interest exempt property in a federal bankruptcy proceeding, based on section 101.112 of the Texas Business Organizations Code?"
Tex. Bus. Orgs. Code § 101.112(e)
The subsection provides that § 101.112 "may not be construed to deprive a member of the benefit of any exemption applicable to the membership interest." Intermediate Texas courts have held LLC interests are not exempt — but the Fifth Circuit found the question "sufficiently close, recurring, and important" to warrant definitive resolution from Austin.

The business implications are substantial. If the Texas Supreme Court rules that LLC membership interests are exempt, it would fundamentally alter asset protection planning for Texas entrepreneurs and shield LLC interests from bankruptcy trustees across the state. If the court rules they are not exempt — consistent with intermediate court holdings — the status quo is preserved, but with authoritative clarity for the first time. Every Texas bankruptcy attorney and business lawyer advising clients on asset protection should monitor this case closely. A ruling is expected within six to twelve months.

National Law Review — Canada v. Sherman Certified Question
Education Law · First Amendment · Free Exercise

Texas Vouchers
and the Religion Question

Two federal lawsuits filed in early March 2026 challenge the Texas Education Savings Account program's exclusion of Islamic private schools. Acting Comptroller Kelly Hancock excluded hundreds of schools accredited by Cognia — citing alleged connections to organizations designated as foreign adversaries or terrorist organizations — even though the Council on American-Islamic Relations (CAIR) has not been designated a terrorist group by the U.S. State Department.

⚖️
Free Exercise Clause
Religious Discrimination Claim
Plaintiffs allege the exclusion targets Islamic institutions specifically, violating the First Amendment's protection against government discrimination based on religious identity.
🏫
Excluded Schools
Cognia-Accredited Islamic Schools
Hundreds of schools accredited by a major national accrediting body were excluded based on asserted — but undesignated — connections to CAIR. No formal federal terrorist designation exists.
👨‍👩‍👧
Disability Access
41-Day Window Too Short
Separately, families of children with disabilities cannot obtain required public school evaluations within the program's 41-day application window — effectively blocking $20,000 in additional ESA funds.

Education law practitioners should note that the Texas ESA program — one of the largest in the nation — now faces simultaneous constitutional and administrative challenges. The exclusion mechanism raises foundational questions about how Texas may condition public benefit programs on associations with religious organizations. For counsel advising religious schools on participation, the outcomes of these lawsuits could determine eligibility for thousands of students statewide.

Houston Public Media — Muslim Schools Sue Texas Over Voucher Exclusion
Election Law · March 2026 Primary

0.7 Points
Separate Them

The Republican U.S. Senate primary — the most expensive in Texas history — ended without a majority winner. Senator John Cornyn and Attorney General Ken Paxton head to a May 26 runoff after a combined nearly $100 million in advertising produced the narrowest of margins. Paxton is vacating the Attorney General's office regardless of the outcome; the GOP AG race now heads to its own runoff between State Sen. Mayes Middleton and U.S. Rep. Chip Roy.

John Cornyn
41.7%
Ken Paxton
41.0%
Wesley Hunt
13.4%
May 26
GOP Senate Runoff
Cornyn v. Paxton. Winner faces Democratic nominee James Talarico in November. Concurrently, Middleton v. Roy in the AG runoff — the result shapes Texas law enforcement direction for the next term.

For the legal community, the AG runoff carries immediate significance: Mayes Middleton brings an energy-sector background and has focused on challenging federal environmental regulation; Chip Roy has emphasized federal power reduction and border enforcement. Both will inherit an office with an expansive enforcement agenda — the incoming AG will immediately face decisions about active federal court challenges and enforcement posture across consumer protection, immigration, and energy.

Texas Tribune — Five Takeaways from the 2026 Texas Primaries
Criminal Law · Regulatory Enforcement · Texas Tribune

Raided, Not Convicted:
The Hemp Legal Grey Zone

Since August 2024, Texas law enforcement agencies have conducted more than 15 raids on hemp-derived THC retailers across the state — seizing inventory, equipment, and cash — without producing a single criminal conviction. The enforcement campaign operates in a legal grey zone created by the 2019 Texas Farm Bill, which legalized hemp but left the THC concentration threshold (0.3% delta-9 THC dry weight) ambiguous for products like edibles, gummies, and vape cartridges made from hemp-derived concentrates.

0 Raids Since
Aug 2024
0 Criminal
Convictions
$0 Seized Assets
Returned
Aug 2024
Enforcement Campaign Begins
Texas law enforcement agencies, citing new DPS guidance, begin treating hemp-derived delta-8 and delta-9 THC products as controlled substances regardless of dry-weight concentration. Retailers receive no advance notice of changed enforcement posture.
Late 2024
Arrests Made, Charges Not Pursued
Multiple business owners arrested during raids. Prosecutors in several counties decline to file charges due to unclear state law on hemp-derived THC products. Seized inventory is not returned despite no prosecution.
Mar 2026
Raids Continue — Legislation Pending
New state regulations on hemp products are expected from DSHS, which could clarify or tighten the law. Defense attorneys advising hemp businesses warn that raids will accelerate before new rules take effect. Business owners report $500,000+ in unrecovered seized inventory.

Criminal defense attorneys representing hemp-derived THC retailers should be prepared for challenges on both sides: Fourth Amendment challenges to the search warrants (probable cause based on THC product presence alone may be legally insufficient where products are compliant with federal hemp law) and civil asset forfeiture challenges where no criminal conviction results. The distinction between legal hemp and illegal cannabis is a laboratory question — and officers often lack field-testing tools that differentiate them.

Texas Tribune — Texas Hemp Businesses Fear Uptick in Police Raids
Second Amendment · Commerce Clause · W.D. Tex.

Texas Gun Club
Targets the 1986 Machine Gun Ban

The Temple Gun Club and three of its members filed a federal lawsuit in the Western District of Texas in March 2026 seeking to invalidate 18 U.S.C. § 922(o) — the 1986 Hughes Amendment to the Firearm Owners Protection Act, which bans civilian ownership of machine guns manufactured after May 19, 1986. The suit argues the federal government lacks authority to criminalize machine gun possession under the Commerce Clause.

Filed
W.D. Tex.
Government
Response
District
Court
Fifth
Circuit
SCOTUS
(Potential)

This case is one of dozens filed nationally in the post-Bruen landscape testing the outer limits of the Second Amendment. Texas practitioners in criminal defense should monitor the district court's treatment of the Commerce Clause argument — while the constitutional theory has long been considered a long shot, the Fifth Circuit's recent Second Amendment jurisprudence (including decisions on bump stocks, untraceable firearms, and domestic violence firearm prohibitions) has made Texas federal courts a primary battleground for firearms constitutional law.

AmmoLand — Temple Gun Club Federal Lawsuit
§
Ex parte Cedric Allen Ricks
No. WR-85,278-02 · Texas Court of Criminal Appeals · Filed March 4, 2026
Court of Criminal Appeals · Capital Habeas

Death Row:
Habeas and the Stay

On March 4, 2026, a subsequent application for writ of habeas corpus was filed in the Texas Court of Criminal Appeals on behalf of death row inmate Cedric Allen Ricks, together with a motion to stay his execution. A subsequent writ — meaning Ricks has filed before — is subject to the "abuse of the writ" doctrine, which requires the applicant to satisfy one of the narrow exceptions set out in Tex. Code Crim. Proc. Art. 11.071 § 5.

01
Filing
Subsequent habeas application filed under Art. 11.071. Because this is not a first application, the Court must first determine whether it satisfies one of the § 5 gateway exceptions before reaching the merits.
02
Gateway Analysis
The CCA evaluates whether the new claims involve previously unavailable legal grounds, factual bases that could not have been previously discovered through due diligence, or actual innocence evidence. Failure to satisfy § 5 results in dismissal without a merits ruling.
03
Stay Motion
Execution stay motions filed alongside subsequent writs face a high bar. The CCA may deny the stay and dismiss the writ in the same order if it finds the gateway requirements unmet. Capital defense attorneys must move quickly — the CCA typically acts on subsequent applications within days of the scheduled execution date.

Texas leads the nation in executions. Capital habeas practice in Texas is extraordinarily compressed — practitioners must master the interplay between state and federal habeas (28 U.S.C. § 2254), exhaustion requirements, and the CCA's aggressive application of Art. 11.071 § 5. The Ricks application is a reminder that subsequent writ practitioners must identify a clear gateway exception in the initial filing — the CCA does not return cases for amendment once the gateway analysis has begun.

Leagle — Ex parte Ricks, No. WR-85,278-02 (Tex. Crim. App. 2026)
Texas AG Race · May 26 Runoff

Two Visions
for Texas Law

With Ken Paxton vacating the Attorney General's office to pursue the U.S. Senate, Texas will have a new AG for the first time since 2015. The Republican nominee — to be determined in the May 26 runoff — will inherit an enforcement agenda spanning immigration, energy regulation, consumer protection, and federal preemption litigation. The two candidates represent meaningfully different legal philosophies.

Mayes Middleton
State Senator · Energy Sector Background
Energy & Environment: Emphasis on resisting federal EPA regulations, supporting oil and gas industry, and challenging federal clean energy mandates that affect Texas producers.
Federal Preemption: Focus on filing multistate suits challenging Biden-era regulatory rollbacks and Biden-era energy transition policies that were paused under the new administration.
Base: Support from energy industry, coastal Texas, rural conservative base. Less focus on social conservative enforcement agenda.
Chip Roy
U.S. Representative · Former AG Staff
Federal Power: Aggressive resistance to federal overreach, has called for defunding federal agencies. Would be expected to lead multistate constitutional challenges to federal spending and regulatory authority.
Border & Immigration: Long-standing national profile on border security. Expected to amplify Texas AG's role in immigration litigation and state-level enforcement support.
Base: National conservative following, Freedom Caucus credibility, strong primary-voter alignment. Former Deputy AG under Paxton provides institutional continuity.

For practitioners in regulated industries — energy, healthcare, financial services — the AG transition matters because Texas's pattern of federal challenge litigation (the office filed more than 40 multistate suits in four years under Paxton) is likely to continue under either candidate, but the target selection and priority areas will shift. Compliance counsel should begin scenario planning around the two enforcement philosophies before the May 26 runoff.

AP News — Texas Primary Results Takeaways
Texas Supreme Court · March 6, 2026

Docket Update:
The Week's Orders

Beyond accepting the certified question in Canada v. Sherman, the Texas Supreme Court's March 6, 2026 orders reflect a court in mid-term stride — denying petitions in the majority of cases, abating two matters pending further development, and dismissing a direct appeal on procedural grounds.

Texas Supreme Court — March 6, 2026 Orders Term: 2025–2026
Cases Granted — Certified Question
Canada v. Sherman — LLC membership interest bankruptcy exemption under Tex. Bus. Orgs. Code § 101.112. Accepted for briefing; ruling expected within 6–12 months.
Cases Abated
In the Interest of S.P.A.T. — Abated pending Case No. 15-0171. Townley v. LVNV Funding, LLC — Removed from active docket until May 5, 2026.
Petitions for Review Denied
Multiple petitions denied across family services, property disputes, and commercial matters statewide. Dallas Police Retired Officers Assoc. v. Dallas Police & Fire Pension System — motion for rehearing denied.
Direct Appeal Dismissed
Jesus Castillo v. H-E-B, LLP — Direct appeal dismissed on procedural grounds. Case remains active in lower courts.

Practitioners awaiting petitions for review denied this cycle should note that the denial of a petition does not constitute a ruling on the merits. The Texas Supreme Court denies the overwhelming majority of petitions — the court grants fewer than 10% of petitions for review each term. If you received a denial, the court of appeals' opinion below is now final for purposes of state law. Consider whether certification of questions to federal courts or legislative solutions are appropriate for recurring issues.

Texas Judicial Branch — March 6, 2026 Orders
What is Legally Brief?