Sunday Edition March 22, 2026 Spring Equinox

IN
EFFECT

The week Texas law moved from the courtroom to the street. Five deadlines. Four rulings. One execution date. Law is no longer pending — it is present.

March 18
SB 12 Drag Ban
Enforced
March 31
Smokable Hemp Ban
9 Days
April 30
Broadnax Execution
39 Days
No. 24-0525
S&B Engineers
5-4 Decided
Scroll
§ 01
Texas Supreme Court · Civil Investigative Demand · March 13, 2026

The State's
Right to Ask

Majority Holding
"The attorney general need only have a reasonable belief — not proof — that an organization possesses information relevant to an investigation to issue a civil investigative demand."
Office of the Attorney General v. PFLAG, Inc.
Texas Supreme Court · No. 24-0xxx · March 13, 2026
Standard
Reasonable belief — not probable cause. The CID need not establish that a violation occurred, only that relevant information may exist.
Why PFLAG
PFLAG's executive director filed an affidavit in a challenge to Texas's gender-affirming care ban, mentioning that families discussed "contingency plans" and "alternative avenues" for care in Texas.
What Produces
Communications about alternative care options, references to healthcare providers, and contingency plans related to transgender youth care. Member identifying information may be redacted or anonymized.
Broader Impact
Texas AG can now investigate advocacy organizations that file affidavits in litigation challenging state law — if those affidavits suggest the organization has relevant information about potential DTPA violations.

The Court reversed the district court, which had blocked the civil investigative demand. A CID under the Deceptive Trade Practices Act (Tex. Bus. & Com. Code § 17.61) is an investigative tool — not a complaint or accusation. But the Court found courts should not second-guess the AG's investigative decisions absent clear abuse. For practitioners advising nonprofit organizations, this ruling substantially lowers the bar for CID compliance: if your client has filed an affidavit in any litigation involving state policy, the AG may now issue a CID on a reasonable-belief standard that courts will rarely review.

Houston Public Media — PFLAG Must Turn Over Records OAG Press Release — CID Authority Affirmed
§ 02
First Amendment · Enforcement Update · Tex. S.B. 12 (88th Leg., 2023)

SB 12:
Day One

This edition's follow-up from last week: on March 18, 2026, Senate Bill 12 moved from pending appellate litigation to active criminal and civil exposure. Performers, venues, and event organizers statewide are now legally subject to enforcement for the first time since the law passed in 2023.

June 2023
SB 12 signed into law (88th Legislature)
Sept 2023
Federal district court enjoins enforcement — law unconstitutional on its face
Feb 25, 2026
Fifth Circuit vacates permanent injunction; limited standing; remands to district court
March 18, 2026
Law takes effect — first criminal and civil exposure for performers and venues
Pending
W.D. Texas: district court remand — facial vs. as-applied analysis continues
Class A
Misdemeanor — Performers
Up to 1 year jail, $2,000 fine
$10,000
Max Civil Fine
Venue Owners
1 Plaintiff
With Standing
Woodlands Pride, Inc.

Practitioners advising performing arts organizations, bars, and event venues must now treat SB 12 as operative law. The Fifth Circuit found only Woodlands Pride has standing — but that ruling does not protect other organizations. Any venue or performer operating in Texas who presents a "sexually oriented performance" as defined by Tex. Bus. & Com. Code § 131 now faces exposure. What constitutes a "sexually oriented performance" is still being litigated; until the district court issues guidance on remand, conservative interpretation is required. Family-friendly drag performances expressly remain legal under the court's analysis.

KUT Radio — Texas Enforces Drag Ban Starting March 18
§ 03
Court of Criminal Appeals · Capital Habeas · Execution: April 30, 2026

Another Man's
Hands

State v. James Broadnax
Dallas County · Convicted 2009 · Capital Murder — Two Victims
0
to scheduled execution

On June 19, 2008 — Juneteenth — two Christian music producers were fatally shot during a robbery in Garland, Texas. Stephen Swan, 26, and Matthew Butler, 28, were killed for $2. James Broadnax, then 19, was convicted and sentenced to death in 2009. His cousin, Demarius Cummings, received life without parole. Both have been imprisoned ever since.

On March 11, 2026 — 50 days before Broadnax's scheduled execution — Cummings signed a sworn confession stating that he, not Broadnax, fired the fatal shots. Cummings claims he persuaded his cousin to take responsibility because Broadnax had no prior record, while Cummings had prior convictions. He states DNA evidence on the murder weapon connects him to the trigger.

01
The Sworn Statement
Demarius Cummings, 37, signed a confession on March 11, 2026, stating he obtained the pistol and fired the fatal shots. The document was submitted to the Dallas County District Attorney's office and the state court of appeals.
02
The DNA Argument
Cummings and Broadnax's legal team argue DNA evidence on the murder weapon is consistent with Cummings having fired it — not Broadnax. They seek independent DNA analysis as part of the stay proceedings.
03
The Legal Pathway
Broadnax's team, led by attorney Steven Herzog, filed emergency appeals seeking a stay of execution and conviction review. A subsequent habeas writ requires satisfying Art. 11.071 § 5 gateway exceptions — actual innocence evidence may qualify.
04
The Additional Claims
Beyond the confession, the appeals also allege racial bias in jury selection under Batson v. Kentucky and prosecutorial misconduct in the use of rap lyrics during trial. Multiple grounds are presented to preserve the broadest possible record.

Capital defense practitioners in Texas must navigate the intersection of the CCA's subsequent writ procedures (Art. 11.071 § 5) and the federal exhaustion requirements of 28 U.S.C. § 2254. A confession by a co-defendant — particularly one who has already been convicted and has nothing to gain — is among the stronger pieces of newly available evidence for actual innocence gateway purposes. The CCA's timeline is compressed; stay motions require immediate action. Broadnax's team must establish that this evidence was unavailable at trial with due diligence.

Dallas Morning News — Cousin Confesses a Month Before Broadnax Execution KERA News — Broadnax Execution and Cousin's Confession
§ 04
Texas Supreme Court · 5-4 · Construction Law · No. 24-0525 · March 13, 2026

Settlement No Longer
Erases Indemnity

In a decision that rewrites a key assumption of Texas construction law, the Texas Supreme Court held 5-4 in S&B Engineers & Constructors, Ltd. v. Scallon Controls, Inc. that a party may pursue contractual proportional indemnification even after settling with the plaintiff — provided the contract's express negligence clause complies with Texas law.

Before This Ruling

Settling a tort claim without the indemnitor's participation effectively extinguished a proportional indemnity claim. Based on Beech Aircraft Corp. v. Jinkins, courts treated settlement as a waiver of downstream indemnity rights.

Settlement = End of Indemnity Claim
24-0525
After This Ruling

A settling party with a proportional indemnity clause may pursue indemnification post-settlement — if the settlement was made in good faith, for a reasonable amount, and the contract expressly indemnifies only the other party's proportionate share of negligence.

Settlement + Contract = Indemnity Survives

The case arose from a 2015 scaffolding accident at a Sunoco refinery that injured seven workers. S&B settled for $6.75 million (contributing $2.35M, with insurer Zurich adding $400K) then sought proportional indemnification from Scallon Controls under their subcontract. Justice Young's majority distinguished this from contribution claims — the contract here allocated liability proportionally, not as a guarantee of full indemnity. The dissent, joined by four justices, warned the ruling "untethers settlement from longstanding precedent" and creates a "case within a case" litigation hazard.

For construction lawyers: review every subcontract's indemnity clause. If it uses proportional language ("to the extent of [party's] negligence" or "allocable share"), it may now survive post-settlement. Clients who settle tort claims against subcontractors should ensure the settlement amount is defensibly reasonable — because that reasonableness will be scrutinized when they pursue indemnity later.

JDSupra — Texas Supreme Court: Indemnity Survives $6.75M Settlement
§ 05
Federal Court · Education Law · Free Exercise · Follow-Up

229,000 Students,
One Court Order

From last week's edition: Texas excluded hundreds of Islamic schools from its Education Savings Account program, citing alleged connections to CAIR (which Governor Abbott designated a terrorist organization in November 2025 — a designation the U.S. State Department has never issued). This week, a federal court responded.

Nov 2025
Abbott CAIR Designation
Early Mar
ESA Exclusion
Mar 12
Lawsuit Filed
!
Mar 17
Judge Bennett Injects
?
Late Apr
Next Hearing
0
Student applications submitted
$1B+
Funding already committed
0
Private schools opted in

U.S. District Judge Alfred Bennett issued a preliminary injunction on March 17, 2026, ordering Texas to extend the voucher application deadline from March 17 to March 31 and to allow previously excluded Islamic schools to register. The court required the state to update its website, prevent determination of funding recipients until after the new deadline, and cease discriminatory application of the CAIR-affiliation exclusion.

Following the order, the state accepted the suing Islamic schools into the program. A second hearing is scheduled for late April to address the constitutional questions: whether the exclusion violates the Free Exercise Clause, Equal Protection, or both. Education lawyers advising religious schools should track the late-April briefing schedule — the outcome may define how Texas may condition public benefit programs on religious associations.

Texas Tribune — Judge Extends Voucher Deadline
§ 06
Property Law · State Sovereignty · Texas-Oklahoma Border · March 8, 2026

The 1999
Line Holds

An Oklahoma district court dismissed a lawsuit in which Bryan County, Oklahoma, landowner Craig Hilliard sought to quiet title to approximately 165 acres of Texas land, claiming that natural accretion along the Red River had shifted the state line southward. Attorney General Paxton invoked sovereign immunity and the 1999 Red River Boundary Compact — and prevailed.

Rejected Authority
1923 SCOTUS Decision
Oklahoma v. Texas (1923)
Boundary = Lower bank of the south bank
The 1923 U.S. Supreme Court decision defined the Texas-Oklahoma border as the lower bank of the Red River's south bank. Hilliard argued that natural accretion had moved this bank point, effectively extending Oklahoma's — and thus his — land into Texas. This interpretation has been superseded.
Superseded — Not Controlling
1999
Compact
Controlling Authority
Red River Boundary Compact
Tex. Gov't Code § 140.003
Approved by Congress · Pub. L. 106-288 (2000)
The 1999 Compact — approved by Congress in 2000 — defines the boundary as the vegetation line of the south bank, eliminating accretion-based shifts. The Compact was a negotiated, congressionally ratified agreement between Texas and Oklahoma. Oklahoma courts have no authority to reopen it through quiet title litigation.
Sovereign Immunity · Compact Controls

Bryan County District Judge Mark R. Campbell dismissed the case on March 8, 2026. A second similar lawsuit by another Oklahoma landowner remains pending. For property lawyers advising clients with land near river boundaries: riparian boundary disputes are a growing category of litigation as rivers shift. The Red River Compact provides a clear resolution in Texas's case — but other Texas waterway boundaries (particularly the Rio Grande) remain subject to ongoing accretion and erosion disputes that lack comparable compact authority.

FOX 4 Dallas — Court Ruling Settles Texas-Oklahoma Red River Fight Texas Scorecard — Red River Land Dispute Update
§ 07
DSHS · Consumable Hemp Program · Effective March 31, 2026

The Smoke
Clears March 31

This edition's follow-up on hemp enforcement: following Governor Abbott's Executive Order GA-56 (September 2025), the Texas Department of State Health Services adopted new hemp regulations on March 2, 2026 — after reviewing 1,400+ public comments. They take effect March 31. Most smokable hemp products will become illegal under a new "total THC" formula.

New Total THC Calculation Formula (Effective March 31)
Total Delta-9 THC = (0.877 × THCA) + Delta-9 THC
This formula captures tetrahydrocannabinol acid, which converts to THC when burned — effectively banning most smokable hemp flower, dabs, and extracts that were previously legal at ≤0.3% delta-9 alone.
License Type
Old Annual Fee
New Annual Fee
Increase
Retailers
$150
$5,000
+3,233%
Manufacturers
$250
$10,000
+3,900%

Edibles remain legal under the new rules — provided they use child-resistant, resealable packaging and comply with enhanced testing and labeling requirements. Age verification (21+, government-issued ID) is mandatory for all hemp purchases. Criminal defense attorneys advising hemp-derived THC retailers should note that the March 31 effective date creates a hard compliance cliff: businesses operating with smokable inventory after that date face enforcement under a significantly clarified legal standard, unlike the grey zone that enabled the 15+ raids since August 2024.

Community Impact — Smokable Hemp Illegal in Texas After March 31 This & That CBD — Texas Hemp Laws 2026 Overview
§ 08
Railroad Commission · Class VI UIC Primacy · Carbon Capture & Storage

Texas Takes
the Wells

The Texas Railroad Commission formally assumed primary enforcement authority over Class VI underground injection wells from the U.S. EPA, with full authority effective December 15, 2025. A Texas Tribune report published March 20, 2026, brought renewed attention to the regulatory shift and its implications for Gulf Coast carbon capture projects.

0
Pending Permit Applications
Transferred from EPA to RRC
6th
State to Receive
Class VI Primacy Nationwide
24+
Months — Prior Federal
Processing Time (Typical)
What Class VI Primacy Means for Texas CCS Projects
Permitting Speed
State-level review replaces dual EPA-RRC authorization. States with primacy (like Wyoming) have demonstrated sub-12-month review timelines. The federal queue stretched to 24+ months.
Gulf Coast Impact
Texas accounts for 64 of 239 pending national federal applications — over a quarter of the national queue. Louisiana declared a moratorium on new Class VI applications in October 2025, creating a competitive advantage for Gulf Coast Texas projects.
Regulatory Oversight
RRC assumes full responsibility for application review, construction oversight, operation monitoring, and long-term site care. EPA retains supervisory authority but is removed from the approval chain.
Investment Implications
For CCS developers seeking final investment decisions in 2026, state permitting provides significant timing advantages. However, energy law practitioners note that federal tax incentive uncertainty (45Q credits) remains the primary constraint on project economics regardless of permitting speed.
Texas Tribune — Texas Takes Over Carbon Storage Permitting Troutman Pepper — Class VI Primacy: What CCS Developers Need to Know
§ 09
Property Law · Religious Freedom · Land Use · Collin County

The Plat
and the Power

Attorney General Paxton wrote to Collin County Commissioners Court on March 12, 2026, asking them to continue denying land plat applications from the East Plano Islamic Center (EPIC) City development — also known as "The Meadow." Paxton's office filed suit in February 2026, alleging that the development's utility district engaged in "illegal annexation of land" designed to evade state oversight and facilitate an Islamic-centric real estate community.

⚖️
Religious Land Use Claims
EPIC City supporters and civil rights organizations argue that singling out an Islamic development for regulatory scrutiny — while similar non-Islamic developments face no comparable AG attention — raises First Amendment Free Exercise and RFRA concerns. Federal courts have been receptive to religious land use claims under RLUIPA (Religious Land Use and Institutionalized Persons Act).
🏛️
The AG's Claim
Paxton's office alleges the development's utility district approved land expansion in a manner designed to circumvent state oversight. The lawsuit focuses on procedural violations in annexation law — not explicitly on religious affiliation — though the targeting of an Islamic project by the same AG who designated CAIR a terrorist organization in a state election year raises obvious questions.
📋
Practitioner Considerations
Real estate lawyers advising religious organizations on large development projects should understand that Texas's AG office has now signaled active interest in the annexation and utility district formation procedures of religious communities. Federal RLUIPA may provide a counterclaim framework if the state's actions are facially neutral but produce discriminatory effects.
The Texan — Paxton Asks Collin County to Deny EPIC City Plat
§ 10
Texas Supreme Court · March 20, 2026 · Weekly Orders

The Week's
Docket

The Texas Supreme Court issued orders on March 20, 2026 — including a per curiam reversal in a family law appeal from Collin County. Beyond the Scallon indemnity ruling and the PFLAG CID decision, this was the Court's third active order week of March.

Case
Court Below
Action
Effect
Theodore Landry v. Janelle Landry
No. 24-0910
5th Court of Appeals
Collin County
Reversed — Per Curiam
Court of appeals' judgment reversed without oral argument (TRAP 59.1). Remanded for proceedings consistent with TXSC ruling.
Cases 26-0038, 26-0129, 26-0132
Various
Petitions Denied
Three petitions for review denied. Denial does not constitute a ruling on the merits; courts of appeals' opinions are now final for state law purposes.
Case 25-0969
Pending
Abated
Petition abated until May 19, 2026. Parties must report status by that date.
Multiple mandamus petitions
Various
Mandamus Denied
Four petitions for writs of mandamus denied. No explanation of grounds per standard practice.

The Court denied five motions for rehearing this week — a reminder that Texas Supreme Court denial rates for rehearing are extremely high. Practitioners whose petitions for review were denied in the March 6 or March 20 orders should evaluate whether the issue has federal constitutional implications (potentially supporting a petition to SCOTUS) or whether the matter is best addressed legislatively or through regulatory channels.

Texas Judicial Branch — March 20, 2026 Orders
§ 11
Looking Forward · Week of March 23, 2026

What's
Coming

The most consequential legal deadlines of the spring converge in the next forty days. Here is what Texas practitioners should be tracking.

March 25–31
DSHS
Hemp Compliance Window Closes
The final week before Texas's smokable hemp ban takes effect. Hemp-derived THC retailers must clear smokable inventory, update labeling, implement age verification, and — if continuing operations — pay dramatically higher licensing fees ($5,000 for retailers; $10,000 for manufacturers).
March 31
DSHS · TXSC
Voucher Application Deadline & Hemp Rules Effective
Two deadlines converge: (1) Texas school voucher program application closes — extended by court order to include Islamic schools; (2) DSHS hemp regulations take effect. Both dates are enforceable. No further extensions are currently ordered.
Late April 2026
Federal Court
Voucher Program — Next Hearing
Judge Alfred Bennett scheduled a follow-up hearing on the Islamic school exclusion challenge. The constitutional questions — Free Exercise, Equal Protection — will be briefed and argued. The outcome may define how Texas conditions public benefit programs on religious associations.
April 30, 2026
CCA
James Broadnax — Scheduled Execution
Broadnax's legal team has filed emergency stays based on cousin Demarius Cummings's sworn confession. The CCA and potentially federal courts must resolve the subsequent writ (Art. 11.071 § 5) and stay motion. If a federal habeas petition is filed, 28 U.S.C. § 2254 exhaustion requirements add time pressure. The Dallas County DA has received the confession; their response will be determinative.
Every Friday
TXSC · CCA
Texas Supreme Court Opinion Days
The Texas Supreme Court and Court of Criminal Appeals release opinions on Fridays through June 2026. The term continues through the end of June. Cases pending oral argument this spring include significant administrative law and property matters. Monitor txcourts.gov for each Friday release.
May 26, 2026
Election Law
Senate Runoff & AG Runoff
Cornyn vs. Paxton for the U.S. Senate. Middleton vs. Roy for Texas Attorney General. Both races have direct legal consequences: the incoming AG immediately inherits 40+ active federal challenge lawsuits, enforcement posture decisions across immigration, environment, and consumer protection.
What is Legally Brief?