Full Opinion

September 28, 2026 The Honorable Donna Campbell, M.D. Chair, Senate Committee on Nominations Texas State Senate Post Office Box 12068 Austin, Texas 78711-2068 Opinion No. KP-0533 Re: Eligibility for service as a commissioner on a governing board of an emergency services district under Health & Safety Code § 775.034 (RQ-0627-KP) Dear Senator Campbell: You ask four questions concerning eligibility to serve on a board of emergency services commissioners or in other capacities in an emergency services district (“ESD”). 1 First, you ask whether a person who neither resides in nor owns land taxable by the ESD may nevertheless serve as an emergency services commissioner by residing in a municipality that “has a tax-supported service or funding agreement with the ESD.” Request Letter at 1. Second, you ask whether municipal taxpayers who live outside the ESD and own no taxable land within it may qualify to serve as a commissioner by virtue of such an agreement. Id. Third, you ask whether an ESD may appoint an otherwise ineligible person “to serve in any advisory, non-voting, or ex officio capacity,” and whether any law constrains “such participation by non-district residents or non- taxpayers.” Id. at 2. Finally, you ask whether Chapter 775 of the Health and Safety Code or any “conflict-of-interest or incompatibility doctrines” prohibit officers or employees of a contracting municipality “from simultaneously serving as an ESD commissioner or in another official or advisory capacity.” Id. All four inquiries require examination of Chapter 775, so we begin with this governing statutory framework. Chapter 775 of the Health and Safety Code governs the creation and administration of emergency services districts. The Texas Constitution authorizes the Legislature to create “special districts to provide emergency services” supported by “a tax on the ad valorem property situated in said districts.” TEX. CONST. art. III, § 48-e. Chapter 775 of the Health and Safety Code implements this 1 See Letter from Hon. Donna Campbell, M.D., Chair, S. Comm. on Nominations, to Hon. Ken Paxton, Tex. Att’y Gen. at 1–2 (Jan. 13, 2026), https://www.texasattorneygeneral.gov/sites/default/files/request- files/request/2026/RQ0627KP.pdf (“Request Letter”). The Honorable Donna Campbell, M.D. - Page 2 constitutional grant of authority. TEX. HEALTH & SAFETY CODE § 775.003. An ESD “is a political subdivision of the [S]tate” vested with authority to, inter alia, contract, appoint officers and employees, levy and collect taxes, and otherwise carry out the chapter’s purposes. Id. § 775.031(a). A board of emergency services commissioners governs a district, id. § 775.036(a)(5), and may contract with a “local government” to provide “services the board considers necessary to provide or obtain emergency services that the district or the local government is authorized to provide,” id. § 775.0366(b). A “[l]ocal government” includes a municipality. TEX. GOV’T CODE § 791.003(4)(A); see also TEX. HEALTH & SAFETY CODE § 775.0366(a) (providing that “local government” has the meaning set forth in section 791.003 of the Government Code). The chapter establishes four mutually exclusive pathways to board membership, each with its own qualifications. See TEX. HEALTH & SAFETY CODE §§ 775.034 (“Appointment of Board in District Located Wholly in One County”), .0341 (“Appointment of Board in Certain Districts Located in More than One County”), .0345 (“Election of Board in Certain Counties”), .035 (“Election of Board in District Located in More Than One County”). Your questions concern the eligibility requirements for commissioners appointed in single-county districts under subsection 775.034(a). See Request Letter 1–2. Under that subsection, a resident citizen of Texas may serve as a commissioner only if the person is “at least 18 years of age,” TEX. HEALTH & SAFETY CODE § 775.034(a)(1), and is either (1) “a qualified voter within areas served by the district,” or (2) “the owner of land subject to taxation in the district,” id. § 775.034(a)(2). Your first two questions require us to construe the distinct eligibility requirements set forth in subsection 775.034(a)(2). See Request Letter at 1. Because these questions substantially overlap, we address them together by applying well-settled principles of statutory interpretation to ascertain the precise meaning of each qualification. I. A person living in a municipality where an ESD provides emergency services may qualify as a commissioner, but ownership of land outside the ESD’s boundaries does not satisfy the requirement of owning “land subject to taxation in the district.” Like courts, we interpret statutes by determining and effectuating the Legislature’s intent, which we primarily “discern from the plain meaning of the words chosen.” In re Est. of Nash, 220 S.W.3d 914, 917 (Tex. 2007). The enacted statutory text itself remains “the truest manifestation of what legislators intended” because it alone is “what constitutes the law.” Alex Sheshunoff Mgmt. Servs., L.P. v. Johnson, 209 S.W.3d 644, 651 (Tex. 2006). When the words are unambiguous, we apply them according to their “plain meaning.” In re D.T., 625 S.W.3d 62, 71 (Tex. 2021). Like courts, “we typically consult dictionaries” to determine the “common, ordinary meaning” of a statutorily undefined term. City of Fort Worth v. Pridgen, 653 S.W.3d 176, 183 (Tex. 2022). And we read a provision’s language “within the context and framework of the statute as a whole, not in isolation.” In re Tex. Educ. Agency, 619 S.W.3d 679, 687 (Tex. 2021). Applying these principles to the circumstances you describe, we examine whether the eligibility requirements in subsection 775.034(a)(2) extend to individuals who neither reside in nor own taxable land inside the ESD’s geographic boundaries. The Honorable Donna Campbell, M.D. - Page 3 A. A person who resides in a municipality where an ESD provides emergency services under a service agreement is “within areas served by the district.” Subsection 775.034(a)(2)(A) permits “a qualified voter within areas served by the district” to serve as an emergency services commissioner. TEX. HEALTH & SAFETY CODE § 775.034(a)(2)(A). We understand your central concern to be whether a municipality lying outside the ESD’s boundaries can nevertheless qualify as part of the “areas served by the district.” 2 See Request Letter at 1. The statute does not define “areas served,” nor does it limit the phrase to the district’s geographic boundaries. See TEX. HEALTH & SAFETY CODE § 775.034. To “serve” typically means “to provide services that benefit or help.” MERRIAM-WEBSTER’S COLLEGIATE DICTIONARY 1137 (11th ed. 2003). An “area” ordinarily refers to “a particular extent of space or surface or one serving a special function” and includes “a geographic region.” Id. at 65. You state that the ESD provides beneficial emergency services in a municipality that is outside the district’s own territory. Request Letter at 1. Under such circumstances, those inside the municipality’s geographic boundaries are “within areas served by the district.” Typically, our analysis would be “at an end,” as the statutory “words unambiguously answer the question at hand.” City of Denton v. Grim, 694 S.W.3d 210, 214 (Tex. 2024). Two briefs we received in response to your request, however, contend that the phrase “areas served by the [d]istrict” refers only to the ESD’s “territorial boundaries, not areas receiving services through municipal contracts.” 3 We find no support for that limitation in the text or structure of Chapter 775. See generally TEX. HEALTH & SAFETY CODE §§ 775.001–.306. Nor may we impose a narrowing construction that the phrase’s plain meaning does not support. See Morath v. Lampasas Indep. Sch. Dist., 686 S.W.3d 725, 735 (Tex. 2024) (providing that a legal text’s “scope should not be restricted without reason to less than the plain language can bear”). Moreover, Chapter 775’s eligibility provisions for other emergency services commissioners universally eschew this “served by” phrasing in favor of residency-related qualifications. See, e.g., TEX. HEALTH & SAFETY CODE §§ 775.0341(d) (requiring commissioners to “reside in the district”), .0345(d) (requiring a commissioner to be “a resident of the district”), .035(c) (stating a commissioner must be “a resident of the district”). We presume the Legislature “uses different words to convey different meanings.” Malouf v. State ex rels. Ellis, 694 S.W.3d 712, 727 (Tex. 2024). The plain meaning of “areas served” in subsection 775.034(a)(2)(A), coupled with this textual contrast with other provisions, demonstrates the Legislature’s affirmative decision to extend eligibility beyond the ESD’s geographic boundaries. The possibility that the service agreement might later end does not alter our conclusion. See Bexar County ESD Briefs at 2 (expressing concern that an appropriation clause might render a sitting commissioner ineligible). Our role “is not to second-guess the policy choices that inform 2 You do not inquire about the meaning of “a qualified voter” for purposes of subsection 775.034(a)(2)(A). See generally Request Letter. We thus leave for another day the precise meaning of that phrase in the context of Chapter 775. 3 Brief from Robert W. Wilson, Esq., Sanchez & Wilson, PLLC, to Hon. Ken Paxton, Tex. Att’y Gen. at 2 (Feb. 11, 2026) (on file with the Op. Comm.); Brief from Robert W. Wilson, Esq., Sanchez & Wilson, PLLC, to Hon. Ken Paxton, Tex. Att’y Gen. at 2 (Mar. 13, 2026) (on file with the Op. Comm.) (collectively “Bexar County ESD Briefs”). The Honorable Donna Campbell, M.D. - Page 4 our statutes or to weigh the effectiveness of their results.” McIntyre v. Ramirez, 109 S.W.3d 741, 748 (Tex. 2003). Nor may our analysis “turn on speculation as to whether the Legislature envisioned a particular result.” 4 Bexar Appraisal Dist. v. Johnson, 691 S.W.3d 844, 848 (Tex. 2024). We must apply subsection 775.034(a)(2)(A) “as written and refrain from rewriting text that lawmakers chose.” Pruski v. Garcia, 594 S.W.3d 322, 325 (Tex. 2020) (internal quotations omitted) (quoting Entergy Gulf States, Inc. v. Summers, 282 S.W.3d 433, 443 (Tex. 2009)). Accordingly, a resident citizen of Texas within a municipality where an ESD provides emergency services under an agreement such as you describe is “within areas served by the district” for purposes of subsection 775.034(a)(2)(A). Presuming the statute’s other qualifications are met, such a person may serve as an emergency services commissioner under that provision. B. Paying municipal taxes that indirectly support an ESD does not render out-of- district property “subject to taxation in the district.” A person who is “the owner of land subject to taxation in the district” may also serve as a commissioner. TEX. HEALTH & SAFETY CODE § 775.034(a)(2)(B). You ask whether a landowner’s indirect contribution to an ESD—through municipal taxes that fund the service contract—meets this qualification. Request Letter at 1. The plain meaning of the phrase “in the district” forecloses such an interpretation. The word “in” ordinarily is “used as a function word to indicate inclusion, location, or position within limits.” MERRIAM-WEBSTER’S COLLEGIATE DICTIONARY 627 (11th ed. 2003). The Legislature’s inclusion of “in” immediately before “the district” thus signifies that the land itself must lie within the geographic boundaries of a district. The surrounding context in Chapter 775 reinforces this reading. Petitions to create, divide, or dissolve an ESD must describe its boundaries with precision. See TEX. HEALTH & SAFETY CODE §§ 775.013(a)(3) (requiring a petition to create an ESD to contain “the proposed district’s boundaries as designated by metes and bounds or other sufficient legal description”), .052(c)(2) (requiring “a description of the district’s boundaries” in a petition to dissolve), .222(d)(2) (requiring “a description of the proposed district’s boundaries” in a petition to divide). That emphasis on district boundaries mirrors the Texas Constitution, which authorizes ad valorem taxation only on “property situated in said districts.” TEX. CONST. art. III, § 48-e. Consistent with that limit, the board must tax “all real and personal property located in the district and subject to district taxation.” TEX. HEALTH & SAFETY CODE § 775.074(a) (emphasis added). This consistent geographic focus demonstrates that land outside an ESD’s boundaries is not “in the district” and cannot satisfy subsection 775.034(a)(2)(B). Accordingly, only land located inside the district qualifies its owner to serve on the board of emergency services commissioners. 4 We note that other provisions in Chapter 775 demonstrate the Legislature’s capability to envision and account for changes in a commissioner’s eligibility. See, e.g., TEX. HEALTH & SAFETY CODE § 775.034(f) (permitting commissioners affected by municipal annexation to complete their terms). The Honorable Donna Campbell, M.D. - Page 5 II. Non-district residents and non-taxpayers appointed to positions other than an emergency services commissioner are not subject to commissioner qualifications but may not exercise the core powers reserved exclusively for commissioners. You next ask whether an ESD may appoint “non-district residents or non-taxpayers” to “advisory, non-voting, or ex officio” positions with the board, and whether Chapter 775 or “other law” imposes “any limits” on their participation. Request Letter at 2. Because your inquiry does not specify the duties or powers of these positions or identify other potentially applicable laws, see id. at 1–2, we can provide only general guidance under Chapter 775, see, e.g., Tex. Att’y Gen. Op. No. KP-0513 (2026) at 1 n.2 (discussing the limited scope of an opinion). An ESD possesses broad authority to “appoint and employ necessary officers, agents, and employees.” 5 TEX. HEALTH & SAFETY CODE § 775.031(a)(3). Nothing imposes the commissioner qualifications set out in subsection 775.034(a)(2) on such appointees or employees. The district may therefore appoint or employ individuals in various roles who are not subject to the same qualifications as commissioners. Chapter 775 does not expressly limit the participation of these officers, agents, or employees. See generally id. §§ 775.001–.306. Any restrictions placed on such participation therefore depend on whether the chapter assigns specific powers exclusively to the commissioners. As a general rule, the powers afforded to members of a local governmental body “involving the exercise of judgment and discretion” may not be delegated absent express statutory authorization. Cf. Guerra v. Rodriguez, 239 S.W.2d 915, 920 (Tex. App.—San Antonio 1951, no writ) (regarding commissioners court authority to hire workers and buy tools and equipment). Chapter 775 grants several specific powers and duties to the board of emergency services commissioners. See TEX. HEALTH & SAFETY CODE § 775.036. Moreover, only commissioners may serve as the board’s president, vice-president, secretary, treasurer, or assistant treasurer. Id. § 775.037(a). And only commissioners may vote to remove a fellow commissioner, alter district boundaries, impose certain taxes, or authorize bonds. See, e.g., id. §§ 775.022, .025, .042, .051, .074, .076, .078, .204. Because Chapter 775 does not authorize delegation of these or other core functions, see generally id. §§ 775.001–.306, non-commissioner appointees and employees may not perform them regardless of their residency or taxpayer status. III. Chapter 775 does not address simultaneous service, but constitutional dual- officeholding restrictions apply when both offices are compensated, and conflicting loyalties incompatibility applies when each position possesses authority to contract with the other government entity. Finally, you ask whether Chapter 775, conflict-of-interest doctrines, or incompatibility doctrines prohibit “a municipal officer or employee . . . from simultaneously serving as an ESD commissioner or in another official or advisory capacity with the district.” Request Letter at 2. You do not identify specific doctrines that might be implicated. See id. By necessity, we limit our 5 An ESD may also employ licensed peace officers and, in specified circumstances, appoint a district fire marshal. See TEX. HEALTH & SAFETY CODE §§ 775.031(c), .036(g), .101. The Honorable Donna Campbell, M.D. - Page 6 conflict-of-interest analysis to Chapter 775 and address simultaneous service under both the Texas Constitution and the common law. A. Chapter 775’s conflict-of-interest provisions do not apply. Two provisions in Chapter 775 address conflicts of interest. First, section 775.104 bars the district fire marshal from holding a financial interest in fire-fighting equipment sales or engaging in fire insurance business. TEX. HEALTH & SAFETY CODE § 775.104. Second, subsection 775.038(d) subjects emergency services commissioners to Chapter 171 of the Local Government Code. Id. § 775.038(d). Chapter 171 requires local public officials to disclose any “substantial interest in a business entity or in real property” and, in some cases, abstain from participation when a matter would have a “special economic effect” on that interest. TEX. LOC. GOV’T CODE § 171.004(a); see also id. §§ 171.003(a)(1) (creating an offense for violations of section 171.004), .005 (restricting participation on budget items involving a member’s substantial business interests). You ask about conflicts that might result from simultaneous service in two governmental roles. See Request Letter at 2. Chapter 775’s conflict-of-interest provisions, however, target only private financial conflicts. Our office previously drew this distinction in the context of Chapter 171, explaining that the chapter governs only conflicts arising from an official’s “nongovernmental, pecuniary interest.” Tex. Att’y Gen. Op. No. GA-0015 (2003) at 4 (quoting Tex. Att’y Gen. LO-95-052 (1995) at 5). Chapter 171 thus resolves the tension between the public duties an officer owes as a member of a governmental body and any personal financial stake the officer may have in a specific matter before that body. Id. By contrast, the type of conflict that results from holding two incompatible public offices involves clashing governmental duties rather than private pecuniary interests. Id. Accordingly, neither subsection 775.038(d) nor section 775.104 applies to your question. B. Constitutional restrictions on dual officeholding may apply depending on the nature of the two positions. The Texas Constitution generally provides that no person may simultaneously “hold or exercise . . . more than one civil office of emolument.” TEX. CONST. art. XVI, § 40(a). “[E]molument” means a “pecuniary profit, gain or advantage.” Tex. Att’y Gen. Op. No. GA-0132 (2003) at 1 (quoting Irwin v. State, 177 S.W.2d 970, 973 (Tex. Crim. App. 1944)). The decisive factor separating a civil or public office from mere public employment is whether the individual is granted a sovereign governmental function to be exercised largely independently for the public’s benefit. State ex rel. Hill v. Pirtle, 887 S.W.2d 921, 931 (Tex. Crim. App. 1994) (orig. proceeding). A person who performs only clerical duties in support of an officer’s powers “is but an agent or employee,” not a public officer. Aldine Indep. Sch. Dist. v. Standley, 280 S.W.2d 578, 583 (Tex. 1955). Commissioners receive compensation, TEX. HEALTH & SAFETY CODE § 775.038(a-1), and Chapter 775 grants them sovereign functions that they exercise with substantial independence, see supra p. 5 (discussing the nondelegable authorities expressly provided to commissioners). Accordingly, this office has previously concluded that an emergency services commissioner holds an office of emolument. See Tex. Att’y Gen. Op. No. GA-1036 (2014) at 1–2. Chapter 775 itself The Honorable Donna Campbell, M.D. - Page 7 confirms this conclusion by providing that a commissioner acting under a service contract “does not, because of that action, hold more than one civil office of emolument.” TEX. HEALTH & SAFETY CODE § 775.0366(c). Moreover, an ESD may “appoint and employ” other “officers” necessary to perform the functions of the district and provide emergency services. Id. § 775.031(a)(3). Article XVI, subsection 40(a) therefore applies to emergency services commissioners and other compensated ESD officers but not to ESD employees or agents. For the prohibition on dual officeholding to operate, however, both positions must qualify as offices of emolument. Tex. Att’y Gen. Op. No. KP-0265 (2019) at 1–2. Your request does not identify the specific “municipal officer or employee” or the type of municipality involved. See Request Letter at 1–2. See generally TEX. LOC. GOV’T CODE §§ 5.001–.005 (distinguishing between municipality types). As a general matter, a compensated municipal office held simultaneously with a compensated ESD office would violate this constitutional prohibition. But subsection 40(a) does not apply if either position is uncompensated or does not constitute a public office. The answer in any specific case depends on the precise character of the positions involved. C. ESD officers and municipal officers with contracting authority hold incompatible offices under the common law doctrine of conflicting-loyalties incompatibility. The common law doctrine of incompatibility has three branches: “self-appointment, self- employment, and conflicting-loyalties.” Tex. Att’y Gen. Op. No. KP-0487 (2025) at 2. Self- appointment incompatibility prohibits officers who possess appointing authority from being appointed to any position they have the power to fill, while self-employment incompatibility bars officers from holding a subordinate position subject to their own supervisory authority. Id. Here, the commissioners court appoints and potentially removes emergency services commissioners. TEX. HEALTH & SAFETY CODE §§ 775.034, .0422. Emergency services commissioners may also remove their fellow members of the board under certain circumstances, id. § 775.042, as well as appoint all other district officers, agents, or employees, id. § 775.031(a)(3). You neither indicate that any municipal officer appoints or removes ESD positions nor that any ESD officer holds such power over municipal positions. See generally Request Letter. And nothing in either your request or Chapter 775 suggests that officers of one entity supervise the personnel of another. See id. See generally TEX. HEALTH & SAFETY CODE §§ 775.001–.306. The analysis therefore reduces to the conflicting-loyalties aspect of the doctrine. Conflicting-loyalties incompatibility bars one person from simultaneously holding two public offices whose duties would prevent the exercise of “independent and disinterested judgment in either or both positions.” Tex. Att’y Gen. Op. No. KP-0407 (2022) at 2 (quoting Tex. Att’y Gen. Op. No. KP-0265 (2019) at 2); see also Thomas v. Abernathy Cnty. Line Indep. Sch. Dist., 290 S.W. 152, 153 (Tex. Comm’n App. 1927, judgm’t adopted). The doctrine’s core inquiries are whether the duties of one office interfere with those of the other and whether simultaneous occupancy would harm the public interest. Pirtle, 887 S.W.2d at 930. Like the constitutional prohibition on dual officeholding, conflicting-loyalties incompatibility applies only to public offices. Tex. Att’y Gen. Op. No. KP-0441 (2023) at 2. But unlike article XVI, subsection 40(a), the offices need not be compensated. Tex. Att’y Gen. Op. No. KP-0462 (2024) at 3. ESD public officers therefore may be subject to conflicting-loyalties incompatibility. Municipal positions such as city council members and mayors also qualify as public officers for incompatibility purposes. The Honorable Donna Campbell, M.D. - Page 8 See Tex. Att’y Gen. Op. Nos. GA-0169 (2004) at 3 (city council members), GA-0132 (2003) at 2 (mayors). City managers and municipal police chiefs, by contrast, generally do not. See Tex. Att’y Gen. Op. Nos. KP-0265 (2019) at 2 (municipal police chief in a home rule city), GA-0766 (2010) at 2 (city managers who serves at the will of the mayor or city council). Because your request does not specify the particular municipal position at issue, only a general analysis is possible. Your inquiry involves an ESD and municipality with boundaries and taxing authority that do not overlap. Request Letter at 1. This geographic separation and inability to tax the same property reduce some potential conflicts. See Tex. Att’y Gen. Op. Nos. KP-0023 (2015) at 2, GA- 0032 (2003) at 5. Nevertheless, “other conflict[s] of discretion or duty may exist.” Tex. Att’y Gen. Op. No. KP-0474 (2024) at 4 (alteration in original) (internal quotations omitted) (quoting Thomas, 290 S.W. at 153). Even when geographic-based potential conflict is absent, two offices may yet be incompatible if “one entity may exert authority contrary to the interests [of] the other.” Tex. Att’y Gen. Op. No. KP-0119 (2016) at 3. Relevant here, you indicate that the ESD and municipality contract with each other. See Request Letter at 1. Emergency services commissioners exercise broad authority to enter contracts on behalf of the district. See, e.g., TEX. HEALTH & SAFETY CODE §§ 775.031(a)(2), .031(a)(10), .0366. And municipal contracts generally require authorization or ratification by the municipality’s governing body. Tex. Att’y Gen. Op. No. JC- 0154 (1999) at 2. Thus, city council members or municipal officers with contracting authority who attempt to serve as emergency services commissioners risk conflicting loyalties under the doctrine of incompatibility. Mutual contracting authority between governmental entities creates a serious and often insurmountable incompatibility of offices. See, e.g., Tex. Att’y Gen. Op. Nos. GA-0786 (2010) at 5, GA-0348 (2005) at 3, JM-1266 (1990) at 4. We have consistently warned against such an arrangement, finding that even the mere prospect of future contracts—without any current agreement—can render the offices incompatible. Tex. Att’y Gen. Op. No. KP-0474 (2024) at 4. Where the mutual contracting authority is “extensive,” the offices may be “incompatible as a matter of law.” Tex. Att’y Gen. Op. No. GA-0786 (2010) at 4. Ultimately, incompatibility depends on the specific facts and the precise nature of the positions involved. See id. As a general matter, however, ESD officers with authority to contract with a municipality and municipal officers authorized to contract with an ESD hold incompatible offices under the conflicting loyalties aspect of the common law doctrine. The Honorable Donna Campbell, M.D. - Page 9 S U M M A R Y To qualify as an emergency services commissioner, Health and Safety Code subsection 775.034(a) requires a person to be either a qualified voter in areas served by the emergency services district or an owner of taxable land within the district. A qualified voter residing in a municipality outside a district’s boundaries that receives emergency services from the district may qualify to serve as a commissioner. However, ownership of property in an area that is served by the district but that is outside the district’s boundaries does not satisfy the requirement that taxable land be within the district. Districts may appoint individuals who are ineligible to serve as commissioners for other roles, but those appointees may not exercise core powers reserved exclusively for commissioners. Chapter 775’s conflict-of-interest provisions do not prohibit a person from serving simultaneously as a municipal officer or employee and as an emergency services district officer or employee. Constitutional dual-officeholding restrictions may prohibit an individual from holding both a compensated municipal office and a compensated emergency services district office. The conflicting loyalties aspect of common law incompatibility generally renders the two offices incompatible when the municipal and emergency services district positions both possess the authority to contract with the other government entity. Very truly yours, KEN PAXTON Attorney General of Texas BRENT WEBSTER First Assistant Attorney General RALPH MOLINA Deputy First Assistant Attorney General D. FORREST BRUMBAUGH Deputy Attorney General for Legal Counsel The Honorable Donna Campbell, M.D. - Page 10 MICHAEL C. COTTON Chair, Opinion Committee