State of Texas, Maxx Juusola, Tracy Martin, and Alan Crider v. City of Dallas, Kimberly Bizor Tolbert, in Her Official Capacity as the Manager for the City of Dallas and the State Fair of Texas
CourtTexas Court of Appeals, 15th District
Date FiledAugust 6, 2026
Docket15-25-00122-CV
StatusPublished
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Full Opinion
Affirmed and Opinion filed August 6, 2026
In The
Fifteenth Court of Appeals
NO. 15-25-00122-CV
STATE OF TEXAS, MAXX JUUSOLA, TRACY MARTIN, AND ALAN
CRIDER, Appellants
V.
CITY OF DALLAS, KIMBERLY BIZOR TOLBERT, IN HER OFFICIAL
CAPACITY AS THE CITY MANAGER FOR THE CITY OF DALLAS AND
THE STATE FAIR OF TEXAS, Appellees
On Appeal from the 298th District Court
Dallas County, Texas
Trial Court Cause No. DC-24-14434
OPINION
Appellant the State of Texas, later joined by appellants Maxx Juusola, Tracy
Martin, and Alan Crider (collectively, “Individual Plaintiffs”), sued the City of
Dallas, Kimberly Bizor Tolbert, in her official capacity as the interim city manager
of the City of Dallas,1 (collectively, “City Appellees”), and the State Fair of Texas
(the “State Fair”), alleging that they unlawfully prohibited licensed gun holders from
carrying handguns onto State Fair grounds. The State and Individual Plaintiffs
(collectively, “Appellants”) sought declaratory and injunctive relief preventing the
City Appellees and the State Fair from implementing the handgun ban. The parties
filed cross-motions for summary judgment on all claims. The trial court issued three
orders granting the City Appellees and the State Fair’s motions, dismissing
Appellants’ claims with prejudice, and denying Appellants’ motion for summary
judgment. Appellants appealed all three orders. Because we hold that the State Fair’s
policy of prohibiting persons from carrying handguns onto its fairgrounds is lawful,
we affirm.
BACKGROUND
The City of Dallas owns Fair Park, which is composed of 277 acres located in
Dallas. In 2003, the City contracted to lease Fair Park to the State Fair of Texas, a
nonprofit corporation.
The State Fair operates the State Fair of Texas exposition at Fair Park, which
is open to the public during September and October of each year, pursuant to the
terms of its lease with the City. In February 2024, the State Fair adopted a new policy
in its rules of conduct prohibiting patrons from carrying firearms onto fairgrounds.
In August of the same year, the Attorney General’s Office received complaints from
individuals about the new policy, one of which came from Individual Plaintiff Maxx
Juusola, asserting this new policy violated the law, including—relevant for our
purposes—Section 411.209 of the Texas Government Code. The Attorney General
initiated an investigation into these complaints and notified the City that it had
1
Tolbert has since been appointed as Dallas’ city manager.
2
violated Section 411.209 and provided it with 15 days to cure the violation. The
Attorney General copied the State Fair on the letter. The City responded to the notice
asserting that it had not violated Section 411.209.
The State then sued the State Fair, the City, and Tolbert in her official capacity
as interim manager of the City. The Individual Plaintiffs later joined the suit on the
side of the State through the First Amended Verified Petition, which sought
temporary injunctive relief preventing City Appellees and the State Fair from
enforcing the State Fair policy banning handguns on Fair Park grounds, among other
things. After holding a hearing, the trial court denied the Appellants’ request for a
temporary injunction. The State filed an interlocutory appeal with this Court and
filed a motion for emergency relief requesting that we effectively enter the
temporary injunction that the trial court denied. This Court denied the State’s
request. The State filed a petition for writ of mandamus challenging this Court’s
decision and another emergency motion for temporary relief, which the Texas
Supreme Court denied.
The State requested that this Court dismiss its temporary-injunction
interlocutory appeal, which we granted. Appellants then filed a third amended
petition in the trial court—the live petition—arguing that the State Fair’s
announcement of its policy barring handguns on fairgrounds violated Section
411.209 and the right to bear arms under Article I, Section 23 of the Texas
Constitution. Appellants also brought an ultra vires claim against Tolbert, arguing
that she acted outside her authority when she allegedly allowed the State Fair to
publish its policy. Appellants sought declaratory and injunctive relief prohibiting
City Appellees and the State Fair from posting Penal Code Section 30.05, 30.06, and
30.07 signs—and any other notice—prohibiting license holders carrying handguns
under the authority of Chapter 411 of the Texas Government Code on fairgrounds
3
and from taking any action banning handguns on fair property.
All parties moved for summary judgment, with the City Appellees and the
State Fair seeking dismissal of all Appellants’ claims and Appellants requesting that
the trial court grant summary judgment in Appellants’ favor on all issues of liability,
injunctive, and declaratory relief. City Appellees and the State Fair also moved to
strike specific summary judgment evidence provided by Appellants. The trial court
in three orders denied Appellants’ motion for summary judgment, granted the State
Fair and the City Appellees’ summary judgment motions, sustained the State Fair’s
objections as to Appellants’ summary judgment evidence, and dismissed the claims
against the State Fair and City Appellees parties with prejudice. Appellants appealed
all three orders, seeking reversal of the trial court’s judgment below and rendition of
judgment in their favor.
STANDARD OF REVIEW
We review the trial court’s order granting summary judgment de novo. Tex.
Dep’t of Crim. Just. v. Levin, 572 S.W.3d 671, 680 (Tex. 2019). “On cross-motions
for summary judgment, each party bears the burden of establishing that it is entitled
to judgment as a matter of law.” City of Garland v. Dall. Morning News, 22 S.W.3d
351, 356 (Tex. 2000). When “the trial court grants one motion and denies the other,
the reviewing court should determine all questions presented” and “render the
judgment that the trial court should have rendered.” Id.
We review a trial court’s decision to exclude summary judgment evidence for
an abuse of discretion. Starwood Mgmt., LLC v. Swaim, 530 S.W.3d 673, 678 (Tex.
2017) (per curiam). “The test for abuse of discretion is ‘whether the court acted
without reference to any guiding rules and principles’ or, stated another way,
whether its decision was arbitrary or unreasonable.” City of San Benito v. Rio Grande
Valley Gas Co., 109 S.W.3d 750, 757 (Tex. 2003) (quoting Downer v. Aquamarine
4
Operators, Inc., 701 S.W.2d 238, 241–42 (Tex. 1985)).
ANALYSIS
The State and Individual Plaintiffs2 raise only one issue on appeal—they
contend that they are entitled to summary judgment as a matter of law on their claim
that the State Fair and the City violated Texas Government Code Section 411.209
when the State Fair issued its policy barring handguns on Fair Park grounds and the
City, as lessor, failed to restrain the State Fair from doing so. Appellants do not
challenge the trial court’s summary judgment dismissal of their other claims against
the City and State Fair. 3 Nor do they challenge the trial court’s dismissal of all claims
against appellee Tolbert. Appellants have thus waived these issues on appeal. Tex.
R. App. P. 38.1(f); Eriksen v. Nelson, 708 S.W.3d 302, 307 n.5 (Tex. App.—15th
Dist. 2025, no pet.). Accordingly, we consider only the State and Individual
Plaintiffs’ Section 411.209 claim against the State Fair and the City.
I. Governmental Immunity Bars the State’s and Individual Plaintiffs’
Section 411.209 Claim against the City.
Texas Government Code Section 411.209 states in relevant part that
[A] state agency or a political subdivision of the state may not take any
action . . . that states or implies that a license holder who is carrying a
handgun under the authority of this subchapter is prohibited from
2
The Individual Plaintiffs in a letter to this Court state that they will rely on the State’s
briefing and do not intend to file a brief of their own.
3
One of those claims concerned the Appellants’ Article 1, Section 23 right to bear arms
claim, wherein Appellants argued that the State Fair and the City “violated this constitutional right
by enforcing policies and restrictions that unlawfully prevent licensed handgun holders and law-
abiding citizens otherwise not prevented from carrying firearms at the State Fair, where such
prohibitions are not legally authorized under law.” We note that nothing in our opinion today
should be construed as saying that governmental thwarting of a citizen’s constitutional right to
bear arms is not a concrete injury—it can be a concrete injury. Heckman v. Williamson Cnty., 369
S.W.3d 137, 155 (Tex. 2012) (stating “[c]onstitutional harms—whether actual or imminent—are
sufficient” to constitute a concrete injury). However, we do not weigh in on this issue here as the
dismissal of this claim is not challenged on appeal.
5
entering or remaining on a premises or other place owned or leased by
the governmental entity . . . .
Tex. Gov’t Code § 411.209(a). The parties do not dispute that the City is a political
subdivision. A political subdivision that violates this provision is liable for a civil
penalty of at least $1,000 for an initial violation and $10,000 for subsequent
violations. Id. § 411.209(b). If the Attorney General determines that legal action is
warranted—after conducting an investigation and giving the political subdivision an
opportunity to cure the violation—the Attorney General may sue to collect the civil
penalty. Id. § 411.209(f)-(g). Normally, “[g]overnmental immunity protects the
State’s political subdivisions, including its cities, against suits and legal liability.”
Dohlen v. City of San Antonio, 643 S.W.3d 387, 392 (Tex. 2022). But “to the extent
of liability created by” Section 411.209, “[s]overeign immunity to suit is waived and
abolished . . . .” Tex. Gov’t Code § 411.209(h).
Appellants argue that the City’s failure to stop the State Fair from
promulgating the firearm ban constitutes an “action” that “states or implies that a
license holder who is carrying a handgun under the authority of this subchapter is
prohibited from entering or remaining on a premises or other place owned or leased
by” the City. See id. § 411.209(a). Appellants contend that after fulfilling the
required statutory prerequisites, the State properly sued the City to collect the civil
penalty. The City Appellees respond that the statutory prerequisites to suit were not
met before the State sued and that that Individual Plaintiffs lack standing. City
Appellees also respond that governmental immunity barred Appellants’ claim
because the City took no “action” prohibiting firearms in Fair Park under Section
411.209; rather, only the State Fair took such action. We agree with the City
Appellees that the Appellants’ Section 411.209 claim is barred by governmental
6
immunity because the City took no prohibited “action” under that provision. 4
Section 411.209(a) targets actions by political subdivisions stating or
implying that license holders carrying handguns are prohibited from entering
property owned by political subdivisions. It is undisputed that the prohibition on
handguns was promulgated by the State Fair, which the parties agree is not a political
subdivision, rather than the City. Appellants do not provide evidence raising a fact
issue, let alone conclusively proving, that the City carried out actions in violation of
Section 411.209. Section 411.209(h) only waives sovereign immunity “to the extent
of liability created by this section.” Id. Because the City did not engage in the
prohibited conduct, it is not liable under that statutory provision. Accordingly,
Appellants’ Section 411.209 claim is barred by immunity.
Appellants first contend that they provided evidence that the City itself
violated Section 411.209, citing a letter the City sent to the Attorney General (the
“City’s Letter”), which the trial court excluded from evidence. The City’s Letter
responded to a previous letter sent by the Attorney General (the “Attorney General’s
Letter”) inquiring into a complaint it had received that the State Fair had prohibited
a peace officer from carrying a weapon onto State Fair premises. The City’s Letter
expressed the City’s commitment to cooperate “with all state of Texas laws
concerning a peace officer’s authority to carry a weapon onto the Fair Park premises
during the State Fair of Texas.” The City’s Letter then stated the State Fair operates
the fair and that it was attaching a letter from the State Fair (the “State Fair’s Letter”)
expressing the same commitment to cooperate with state law regarding a peace
officer’s authority to carry a weapon on Fair Park premises.
4
As governmental immunity disposes of this issue, we do not address whether all statutory
prerequisites were satisfied prior to filing suit or whether Individual Plaintiffs have standing with
respect to their claim against the City.
7
Contrary to what Appellants claim, the trial court did not abuse its discretion
in excluding this evidence because it is not relevant to Appellants’ Section 411.209
claim. “Evidence is relevant if: (a) it has any tendency to make a fact more or less
probable than it would be without the evidence; and (b) the fact is of consequence
in determining the action.” Tex. R. Evid. 401. “Irrelevant evidence is not
admissible.” Tex. R. Evid. 402. The City’s Letter does not “make a fact more or less
probable than it would be without the evidence.” As an initial matter, the City’s
Letter does not concern prohibiting handguns onto Fair Park grounds under Section
411.209 but the opposite—it concerns allowing such handguns when carried by
peace officers. Indeed, the Attorney’s General’s Letter states that Section 411.209 is
inapplicable to peace officers, which the City Appellees do not dispute. The City’s
Letter does not purport to speak on behalf of the State Fair, instead noting that the
State Fair operates the fair and not the City. The State Fair wrote its own letter, which
the City attached to the City’s Letter. Nothing in the City’s Letter indicates that it
controlled or otherwise directed the State Fair’s response. Accordingly, the trial
court’s decision to exclude the City’s Letter was not “arbitrary or unreasonable” and
was in conformance with the rules of evidence. City of San Benito, 109 S.W.3d at
757; Caffe Ribs, Inc. v. State, 487 S.W.3d 137, 142 (Tex. 2016) (“We review a trial
court’s exclusion of evidence under the abuse of discretion standard.”).
Second, Appellants argue that the City violated Section 411.209 because the
State Fair promulgated the handgun ban on City property. Appellants contend
Section 411.209’s prohibition should be understood as a property right restriction on
a political subdivision that passes onto any private entity who leases the property
from the City. In support, Appellants cite case law standing for the proposition that
a lease cannot grant a lessee a greater estate or right than is owned by the lessor and
that Section 411.209 imposes a restriction on the City’s property rights. See, e.g.,
8
Geary v. Two Bow Ranch Ltd. P’ship, No. 04-18-00610-CV, 2020 WL 354763, at
*9 (Tex. App.—San Antonio Jan. 22, 2020, pet. denied) (mem. op.) (stating a
mineral estate lessor could not lease to lessee a greater mineral estate than it owned).
Appellants also cite Proctor v. Andrews, 972 S.W.2d 729, 733 (Tex. 1998),
recognizing that a home rule city’s powers may be limited by statute when the
Legislature limits such powers with unmistakable clarity. Appellants contend that
the State Fair’s handgun ban therefore cannot be implemented on City property.
Notably, Appellants do not argue that the State Fair’s implementation of the ban
itself violates Section 411.209. Rather, Appellants argue that the City’s provision of
leasehold rights to the State Fair, to the extent the State Fair is relying on the lease
terms to enact its handgun ban, constitutes an act by the City in violation of Section
411.209.
This characterization of Section 411.209’s prohibition inhering in the property
does not follow from the text of Section 411.209, which focuses on prohibiting
government conduct. Section 411.209 uses active language to say a state agency or
a political subdivision “may not take any action . . . that states or implies that a
license holder who is carrying a handgun . . . is prohibited from entering or remaining
on a premises or other place owned or leased by the governmental entity . . . .” Tex.
Gov’t Code § 411.209(a) (emphasis added). Section 411.209 prevents the City from
engaging in conduct prohibiting licensed gun holders from carrying handguns on
Fair Park premises. It does not place a restriction on the government property itself.
The Legislature knows how to place restrictions on property. Section 46.03 of
the Texas Penal Code, titled “Places Weapons Prohibited,” bars the possession of
firearms “on the premises of a polling place on the day of an election,” “on the
premises of any government court or offices utilized by the court,” “on the premises
of a racetrack,” “in an amusement park,” and other places. Tex. Pen. Code
9
§ 46.03(a). These prohibitions reside in the properties themselves and are not
contingent on the conduct of the owners or possessors of these properties. “When
the Legislature expresses its intent regarding a subject in one setting, but, as here,
remains silent on that subject in another, we generally abide by the rule that such
silence is intentional.” Liberty Mut. Ins. Co. v. Adcock, 412 S.W.3d 492, 497 (Tex.
2013). Given that the Legislature has placed firearms prohibitions that reside in
properties in Section 46.03 of the Penal Code, we assume the Legislature’s omission
of such property restrictions from Section 411.209 “is intentional.”5 Id.
Here, Appellants’ argument that the City’s leasing Fair Park to the State Fair
violates Section 411.209 rests on the contention that Section 411.209’s handgun ban
prohibition inheres in the City’s property. The State Fair’s handgun ban is prohibited
because it is being enacted on City property and the City in turn is acting unlawfully
because it is maintaining a lease where such a ban is in place. Because, as established
above, Section 411.209’s handgun ban prohibition applies only to the conduct of
state agencies and political subdivisions and not private entities, the State Fair’s
handgun ban does not violate the statute. But even if the State Fair itself had liability
here, Appellants acknowledge that the lease itself “is silent regarding license holders
carrying handguns on the premises of Fair Park . . . .” “Action” means “doing
something.” Action, BLACK’S LAW DICTIONARY (12th ed. 2024). The lease’s silence
on this matter amounts to passivity by the City, which is the opposite of “doing
something.” Accordingly, the City is not violating Section 411.209 by leasing its
5
Appellants assert that the City Appellees and the State Fair take the position that Section
411.209 is inapplicable here because it only applies when a government entity is a lessee on private
property. However, neither City Appellees nor the State Fair make this argument. Both agree that
Section 411.209 applies to the Fair Park grounds because the City owns it and Section 411.209
undisputedly applies to “premises or other place[s] owned . . . by the governmental entity.” What
they contest is whether the City engaged in conduct violating Section 411.209—a showing
required for immunity to be waived for Appellants’ claim. Appellants have failed to raise a fact
issue that the City has engaged in such violative conduct.
10
property to the State Fair.
Relatedly, Appellants argue that the City “has implicitly acted to exclude
license holders carrying handguns from Fair Park through its tacit ratification of [the
State Fair’s] exclusionary policy.” Appellants argue that the City’s shared
understanding with the State Fair that the Fair Park lease does not prohibit the State
Fair’s handgun ban and the City’s failure to restrain the State Fair from enacting the
ban constitutes an implicit ratification of the State Fair’s interpretation of its rights
under the lease. Appellants contend this implicit ratification constitutes an action by
the City that implies that license holders carrying handguns are prohibited from
entering Fair Park grounds in violation of Section 411.209.
“Ratification is the adoption or confirmation by a person with knowledge of
all material facts of a prior act which did not then legally bind him and which he had
the right to repudiate.” BPX Operating Co. v. Strickhausen, 629 S.W.3d 189, 196
(Tex. 2021) (quoting Wise v. Pena, 552 S.W.2d 196, 199 (Tex. App.—Corpus
Christi–Edinburg 1977, writ dism’d)). “It ‘is but an agreement, express or implied,
by one to be bound by the act of another performed for him.’” Id. (quoting
Dillingham v. Anthony, 11 S.W. 139, 142 (1889)). Whether one party has ratified
changes to a contract requires said party to have the intent to adopt the unauthorized
act in question with a full knowledge of the facts. Id. In determining whether an
implied ratification occurred, courts “look to objective evidence of intent, such as
the party’s conduct,” which requires an examination of the totality of the
circumstances. Id. at 197. “To avoid undue interference with a party’s right to reject
contract terms to which he does not agree,” id., implied ratification should only be
found where words or actions “clearly evidenc[e] an intention to ratify.” Id. at 197
(quoting Chrisman v. Electrastart of Hous., Inc., No. 14-02-00516-CV, 2003 WL
22996909, at *5 (Tex. App.—Houston [14th Dist.] Dec. 23, 2003, no pet.) (mem.
11
op.) (alteration in original)).
Appellants have failed to present evidence raising a genuine issue of fact that
would support a finding that the City implicitly ratified the State Fair’s handgun ban.
The City’s Letter responding to the Attorney General’s Letter discussed above, does
not “clearly evidence” an intention to ratify the State Fair’s ban. The City’s Letter—
and the attached State Fair’s Letter—do not pertain to enforcement of the ban.
Rather, they express a commitment to allow, not prohibit, peace officers to carry
handguns in Fair Park. These letters do not involve any alteration to the terms of the
Fair Park lease made by either party through word or deed. Moreover, neither the
City’s mere agreement with the State Fair’s understanding of the lease that it can
implement a handgun ban nor the City’s lack of action to restrain the State Fair from
implementing the ban constitute adoptions of an unauthorized act. As noted earlier,
Appellants concede the lease “is silent regarding license holders carrying handguns
on the premises of Fair Park . . . .” Appellants in effect contend that the City’s
inaction as to the State Fair’s conduct constitutes an adoption of the State Fair’s own
actions. But Appellants do not provide evidence of how such inaction, looking at the
totality of the circumstances, corroborates an intent by the City to adopt the State
Fair’s policy.
The evidence in the record in fact points in the other direction. State Fair
president Mitchell Glieber testified that “nobody” from the City was involved in the
decision-making process in developing the ban, and he denied that the City in any
way ever “endorsed, come out and said, we’re behind you, we support the policy
. . . .” The City in its response to the Attorney General’s pre-suit notice also asserted
that “[t]he City does not participate in [the State Fair’s] decision-making, nor does
the City exercise oversight of [the State Fair’s] decisions. Similarly, [the State Fair]
has sole responsibility for enforcing its rules and regulations regarding the Fair.”
12
The City has maintained this position throughout this litigation. Accordingly, we
hold that the City Appellees are entitled to summary judgment as a matter of law
because governmental immunity bars the State and Individual Plaintiffs’ Section
411.209 claim against the City.
Finally, while it is not controlling, we are mindful of then Justice Blacklock’s
concurrence to the Texas Supreme Court’s denial of the State’s mandamus petition
earlier in this case’s history. Then Justice Blacklock concluded that the State’s
“allegations that the City controls the [State] Fair amount only to scattered and
indeterminate financial connections between the entities, not the kind of control that
would make the State Fair’s decisions about guns imputable to the City.” In re State,
698 S.W.3d 904, 905 (Tex. 2024) (original proceeding) (Blacklock, J., concurring).
Justice Blacklock acknowledged that “[t]he factual landscape could certainly change
as this litigation proceeds” but that “at this stage, every indication is that the State
Fair’s private board made its own decision to prohibit guns at this year’s Fair.” Id.
at 905. The problem for Appellants is that the case is now at the summary judgment
stage, and the factual landscape has not changed. The City’s Letter does not evidence
the City’s influence on the creation or implementation of the State Fair’s gun ban.
Rather, Mr. Glieber’s testimony and the City’s position throughout this dispute
indicate the opposite—the decision was made by the State Fair alone. Justice
Blacklock concluded at the time that “it [was] not possible for an impartial court to
conclude at this stage of the case that anything like” the City’s impermissible control
or influence over the State Fair’s gun policy “ha[d] happened.” Id. As it was then,
so too is it today.
II. The State Fair is Entitled to Summary Judgment on the State and
Individual Plaintiffs’ Section 411.209 Claim.
Appellants assert that the State Fair violated Section 411.209 because the
13
City’s failure to prevent the State Fair from implementing the handgun ban and the
City’s leasing its property to the State Fair while the ban is in place constitute actions
by the City in violation of Section 411.029. The State Fair responds that the City did
not engage in any action that violates Section 411.209. The State Fair further
responds that Individual Plaintiffs lack standing to bring their claim. We hold that
the State and Individual Appellants fail to raise a fact issue that the State Fair violated
Section 411.209 and that the State Fair is therefore entitled to summary judgment on
this claim as a matter of law.
As an initial matter, we examine the State Fair’s challenge to Individual
Plaintiffs’ standing to bring their claims. Rattray v. City of Brownsville, 662 S.W.3d
860, 869 (Tex. 2023) (“[T]he court may not move to the merits if even one
jurisdictional argument remains unresolved.”). “The Texas standing requirements
parallel the federal test for Article III standing, which provides that ‘[a] plaintiff
must allege personal injury fairly traceable to the defendant’s allegedly unlawful
conduct and likely to be redressed by the requested relief.’” In re Abbott, 601 S.W.3d
802, 807 (Tex. 2020) (orig. proceeding) (per curiam) (alteration in original) (quoting
Heckman v. Williamson Cnty., 369 S.W.3d 137, 154 (Tex. 2012)). The State Fair
argues that Individual Plaintiffs lack standing because they cannot bring a claim
under Section 411.209. Specifically, the State Fair contends that Section 411.209
only gives “the attorney general or the appropriate county or district attorney” the
authority to “sue to collect the civil penalty” for violating the statute. See Tex. Gov’t
Code § 411.209(g).
The State Fair confuses the issue of standing with the issue of capacity. “A
plaintiff has standing when it is personally aggrieved, regardless of whether it is
acting with legal authority; a party has capacity when it has the legal authority to
act, regardless of whether it has a justiciable interest in the controversy.” Pike v. Tex.
14
EMC Mgmt., LLC, 610 S.W.3d 763, 775 (Tex. 2020) (quoting Coastal Liquids
Transp., L.P. v. Harris Cnty. Appraisal Dist., 46 S.W.3d 880, 884 (Tex. 2001)). A
plaintiff lacks capacity when he “is not entitled to recover in the capacity in which
he sues.” Id. (quoting Tex. R. Civ. P. 93(2)). Here, the State Fair asserts that
Individual Appellants lack the legal authority to bring this suit and that only “the
attorney general or the appropriate county or district attorney” may do so. But “[l]ack
of capacity is not a jurisdictional defect.” Rodriguez v. Ovation Servs., LLC., No. 14-
25-00472-CV, 2026 WL 1953530, at *3 (Tex. App.—Houston [14th Dist.] July 7,
2026, no pet. h.) (mem. op.); Coastal Liquids, 46 S.W.3d at 884 (“A party must have
both standing and capacity to bring a lawsuit. And while standing as an issue cannot
be waived, capacity can be.”). As the State Fair is not substantively challenging
subject matter jurisdiction as to Individual Appellants’ claim against the State Fair,
we proceed to the merits. Rattray, 662 S.W.3d at 869. In proceeding to the merits,
we do not address the State Fair’s capacity argument today because, even assuming
Individual Appellants have capacity, the fact that Section 411.209 does not provide
a cause of action against the State Fair that can be brought by either the State or
Individual Appellants disposes of this issue.
The State and Individual Appellants do not articulate how the State Fair’s
conduct violates Section 411.209. Appellants argue that the City’s failure to stop the
State Fair from implementing the handgun ban and maintaining a lease with the State
Fair when the ban was in place are violations by the City. The State Fair’s gun ban
serves as the basis for how the City’s conduct allegedly violates Section 411.209,
but Appellants do not explain how the State Fair violated that provision through
implementing its ban. As discussed above, see supra Part I, Section 411.209 only
prohibits the actions of “state agenc[ies]” and “political subdivision[s] of the state”
seeking to ban licensed gun holders from carrying handguns on government
15
property. Tex. Gov’t Code § 411.209(a). It does not apply to private entities such as
the State Fair.
CONCLUSION
We affirm the trial court’s judgment dismissing Appellants’ claims with
prejudice.
/s/ April Farris
April Farris
Justice
Panel consists of Chief Justice Brister and Justices Field and Farris.
16