Reply Brief on Remand for Defendant/Appellant

    IN THE UNITED STATES COURT OF APPEALS 

FOR THE FIFTH CIRCUIT 

  

NO. 90-8014 and 
NO. 90-9003 

  

LEAGUE OF UNITED LATIN AMERICAN CITIZENS, 
COUNCIL NO. 4434, et al., 

Plaintiffs-Appellees, 

versus 

WILLIAM P. CLEMENTS, GOVERNOR OF THE STATE 
OF TEXAS, et al., 

Defendants-Appellants, 

JUDGE SHAROLYN WOOD, 

Defendant-Appellant. 

  

Appeal from the United States District Court 
for the Western District of Texas 

Midland Division 

  

REPLY BRIEF ON REMAND FOR DEFENDANT/APPELLANT 

HARRIS COUNTY DISTRICT JUDGE SHAROLYN WOOD 

  

PORTER & CLEMENTS 

J. Eugene Clements 

Evelyn V. Keyes 
3500 NCNB Center 

P.O. Box 4744 

Houston, Texas 77210-4744 

Phone: (713) 226-0600 

Fax: (713) 228-1331 

ATTORNEYS FOR DEFENDANT/APPELLANT 
JUDGE SHAROLYN WOOD 

 



    

IN THE UNITED STATES COURT OF APPEALS 
FOR THE FIFTH CIRCUIT 

  

NO. 90-8014 and 
NO. 90-9003 

  

LEAGUE OF UNITED LATIN AMERICAN CITIZENS, 
COUNCIL NO. 4434, et al., 

Plaintiffs-Appellees, 

Versus 

WILLIAM P. CLEMENTS, GOVERNOR OF THE STATE 
OF TEXAS, et al., 

Defendants-Appellants, 

JUDGE SHAROLYN WOOD, 

Defendant-Appellant. 

  

Appeal from the United States District Court 
for the Western District of Texas 

Midland Division 

  

REPLY BRIEF ON REMAND FOR DEFENDANT/APPELLANT 
HARRIS COUNTY DISTRICT JUDGE SHAROLYN WOOD 

  

PORTER & CLEMENTS 

J. Eugene Clements 
Evelyn V. Keyes 

3500 NCNB Center 

P.O. Box 4744 

Houston, Texas 77210-4744 

Phone: (713) 226-0600 

Fax: (713) 228-1331 

ATTORNEYS FOR DEFENDANT/APPELLANT 
JUDGE SHAROLYN WOOD 

 



    
TABLE OF CONTENTS 

  

Page 

ARGUMENT AND AUTHORITIES. =. . . os Je bivieie sn sti wie sawiiiny n 2 

lL. APPELLEES HAVE FAILED TO ADDRESS THE CRUCIAL ISSUES 
ONREMAND. i... a... Bis, yn De Bh, 2 

II. APPELLEES MISCONSTRUE THE LINKAGE BETWEEN TEXAS 
STATE DISTRICT JUDGES’ ELECTORAL DISTRICTS AND THEIR 
JURISDICTION, ri... ies cin rat il, Lo Sa 5 

CONCLUSION od. oh. re i Fy adr RET a 2) 

 



      

TABLE OF AUTHORITIES 

Cases Page 

Alfaro v. Dow Chemical, 751 S.W.2d 208, 211 (Tex. App. — Houston 
[1st Dist.] 1988), ¢/f’'d 736 S.W.2d 674 (Tex. 1990) .. .... vv oi vs vuvun. 6 

Boyd v. Thayer, 143 U.S. 135,161, 12'S. Ct. 375, 381-82.(1892) . . i ou dv 20 wg 4 

Bradas v. Rapides Parish Police Jury, 508 F.2d 1109, 1112 
SN CI Og, ris ee cries i es feds a Tl ae 5 

Cleveland v. Ward, 116 Tex. 1,285 SW. 1063 i... 0. i's Jia i mh 5 ed 6 

East Carroll Parish v. Marshall, 424 U.S. 636 (0976) ... v. .. uo des dui 5 

Gregory v. Ashcroft, U.S. , LIU S. CL A3IS UI) +. i. ihe svn sins 3, 4 

Houston Lawyers Ass’n v. Attorney General of Texas, 
U.S. ry d11 S.Ct. 2376, 2380 (19M) (ius vies ie ah 2:3 

LULAC Council No. 4434 v. Clements, 914 F.2d 620 (1990) 
and 902 F.2d 203.1000)..." + cis EE, Se HS i 3 

Morrow v. Corbin, 62 S.W.2d 641 (Tex, 1933)... . 0 us vi oo ii ee si Bodies 6 

Oregon v. Mitchell, 400 U.S. 112, 91 S. Ct. 266 (L970) ©. 0% 0 Sah en 3 

Wallace v. House, S1S F.2d 619,634 (Sth Cir. 1975), VAC. +... vv uv viiv ennai 5 

Whitcomb v. Chavis, 403 U.S. 124,918. CL. 1888 (AVF) 5. . . vv us divas E00 5 

White v. Regester, 412U.8,:785, 938. Ct. 23320972) .. . . ooo iu vii dais ivain 5 

Zimmer v. McKeithen, 485 F.2d 1297 (5th Cir. 1973), 
aff°d sub nom East Carroll Parish v. Marshall, 
AAS. 3B (1070)... li tenis a CRS BBE 5 

ii 

 



Statutes 

Federal 

42 U.S.C.A. § 1973 

tate Mal dA 

. CIv. PRAC. & REM. CODE ANN. § 51.001 (West 1986) 

. CIv. PRAC. & REM. CODE § 15.084 

. CRIM. PROC. CODE ANN. ART. 4.16 (West 1977) 

. GOV'T CODE ANN. ART. 27.031 

. GOV'T CODE ANN. ART. 74.056 (West 1988) 

. GOV'T CODE ANN. ART. 74.057 (West 1988) 

. GOV'T CODE ANN. ART. 74.094(a) (West 1991) 

. Gov’T CODE § 22.001 

. Gov’T CODE § 22.220 

.'R..Cv. P. 330. 

«.R. CV, P. 554 

. R. Cv. P. 574b 

Constitutions 

Federal 

U.S. CONST. ART. IV § 4 and AMEND. X 

State 

TEX. CONST. ART. V § 2 

TEX. CONST. ART. V § 6  



    

IN THE UNITED STATES COURT OF APPEALS 
FOR THE FIFTH CIRCUIT 

  

NO. 90-8014 and 
NO. 90-9003 

  

LEAGUE OF UNITED LATIN AMERICAN CITIZENS, 
COUNCIL NO. 4434, et al., 

Plaintiffs-Appellees, 

Versus 

WILLIAM P. CLEMENTS, GOVERNOR OF THE STATE 
OF TEXAS, et al., 

Defendants-Appellants, 

JUDGE SHAROLYN WOOD, 

Defendant- Appellant. 

  

Appeal from the United States District Court 

for the Western District of Texas 

Midland Division 

  

REPLY BRIEF ON REMAND FOR DEFENDANT/APPELLANT 
HARRIS COUNTY DISTRICT JUDGE SHAROLYN WOOD 

  

ADDRESS TO THE COURT: 

Defendant/ Appellant Harris County District Judge Sharolyn Wood ("Judge Wood") files 

this Reply Brief on Remand to show the Court that the linkage between county-wide Texas 

 



  

   
District judge electoral districts and jurisdiction is a fundamental State interest which outweighs 

any finding of non-discriminatory vote dilution under § 2 of the Voting Rights Act. 

ARGUMENT AND AUTHORITIES 

L. APPELLEES HAVE FAILED TO ADDRESS THE CRUCIAL ISSUES ON REMAND. 

Appellees the Houston Lawyers Association ("HLA"), er al. and the League of United 

Latin American Citizens ("LULAC"), er al., apparently assume, erroneously, that this case was 

correctly decided below on the law and the facts, and that all that remains is for this Court to 

remand the case to the district court for imposition of a remedy. This is incorrect. As 

remanded by the Supreme Court to this Court, this case is one of first impression as to the 

application of § 2 to single-member officeholders in the judicial branch of state government. 

Writing for the Supreme Court majority, Justice Stevens observed that the Supreme Court 

had taken this case for the limited purpose of deciding whether judges were "representatives" 

for purposes of applying § 2 of the Voting Rights Act, 42 U.S.C.A. § 1973. Houston Lawyers 

Ass'n v. Attorney General of Texas, US. __ ,1118. Ct. 2376, 2380 (1991). The Court 

determined that elected judges are representatives for purposes of § 2 and therefore reversed the 

en banc majority opinion of this Court. The Court went on to discuss, however, the theory 

expressed in Judge Higginbotham’s concurrence that Texas district court judgeships are 

single-member offices in which the jurisdiction of the court and the elective base of the judge 

acting alone are co-extensive. The Court noted the concurrence’s fear that attempting to break 

the linkage between jurisdiction and elective base to correct for vote dilution in judicial races 

might well violate a compelling state interest and lessen minority influence instead of increasing 

it. Id. 

 



  

   
While disagreeing with this Court "that the single-member office theory automatically 

exempts certain elections from the coverage of § 2," or that "the State’s interest in maintaining 

an at-large, district-wide electoral system for single-member offices . . . automatically, and in 

every case, outweigh(s] proof of racial vote dilution," the Supreme Court expressly stated, "We 

deliberately avoid any evaluation of the merits of the concerns expressed in J udge 

Higginbotham’s concurring opinion." 111 S. Ct. at 2380-81. It then remanded the case to this 

Court to consider the merits of the concerns expressed in the concurrence, explicitly recognizing 

that: 

the State’s interest in electing judges on a district-wide basis may preclude a 
remedy that involves redrawing boundaries or subdividing districts, or may even 
preclude a finding that vote dilution has occurred under the "totality of the 
circumstances. " 

111 S. Ct. at 2380. 

Responding to the Supreme Court’s directive and to this Court’s questions, Judge Wood 

argued at pages 27-37 of her Brief on Remand that the trial court misjudged the weight to be 

assigned the State of Texas’ interest in structuring its own judiciary. The authorities cited by 

Judge Wood — chief among them Oregon v. Mitchell, 400 U.S. 112, 91 S. Ct. 266 (1970), 

Gregory v. Ashcroft, ___ U.S. | 111 S. Ct. 2395 (1991) and the en banc and panel opinions 

in this case, LULAC Council No. 4434 v. Clements, 914 F.2d 620 (1990) and 902 F.2d 293 

(1990) — establish as a matter of law that a state’s interest in structuring its own judiciary lies 

at the core of our federal system and is protected by the Guaranty Clause and the Tenth 

Amendment to the United States Constitution. U.S. CONST. ART. IV § 4 and AMEND. X. Only 

a violation of an even more compelling interest can override and usurp this state function. The 

right of minorities to force the restructuring of the state judiciary in order to elect judges chosen 

 



    

only by minority voters — the right asserted by Appellees — fails to override the guarantees of 

the United States Constitution that ensure the rights of all citizens of a state to "prescribe the 

qualifications of its officers and the manner in which they shall be chosen." Gregory, 111 S. 

Ct. at 2400-01 (quoting Boyd v. Thayer, 143 U.S. 135, 161, 12 S. Ct. 375, 381-82 [1892]). 

Congress itself — as the plain wording of § 2 and legislative history of the 1982 amendments 

irrefutably demonstrate — never thought it had given itself such power. Appellees failed to 

show that Texas’ district judge election system has dilutive results, but even if they had, a 

showing of unintentional vote dilution would not justify the extreme intrusion on state core 

functions sought Appellees. Moreover, the only "remedies" proposed by the Appellees have 

gravely anti-democratic results. These are the issues on remand. 

Appellees seek remand to the district court on the ground that Texas’ interest in 

county-wide single-judge district trial courts has already been found to be insubstantial.” In 

  

! Judge Wood argued in her Brief on Remand that subdistricting would disenfranchise all 
voters - including minority voters — in virtually all judicial races. Judge Wood’s Brief on 
Remand at 31. This echoed an observation made in the panel opinion in this case, 902 F.2d 
307, the en banc opinion, 914 F.2d at 649, and the Supreme Court Opinion, 111 S. Ct. at 2380. 

Judge Wood commends the Brief of Amici Curiae the State of Alabama to the Court’s 
attention for a thorough analysis of the competing interests to be weighed in assessing a vote 
dilution claim brought against the state judiciary and the effect of adopting subdistricting, limited 
and cumulative voting systems for judicial elections. 

? The United States argues that this case should be remanded for consideration of the 
weight of the State’s interest in structuring its judicial election system. This is a wholly 
inappropriate request under the circumstances of this case. The State of Texas’ interest in the 
structure of its district judge elections was the subject of extensive testimony at trial. See Judge 
Wood's Brief on Remand at 4-7. Judge Bunton considered this evidence in reaching exhaustive 
findings of fact and conclusions of law, which he set out in a 94 page Memorandum Opinion 
and Order on November 8, 1989. ("Op.") The question for this Court is, therefore, whether 
Judge Bunton erred in concluding, as he did, on the basis of the evidence before him, that the 
State of Texas’ interest in the structure of its judicial election system was not compelling and 
that its interest in maintaining that structure did not outweigh the rights of minority voters under 

4 

 



    

support of their argument, Appellees rely on Wallace v. House, 515 F.2d 619, 634 (5th Cir. 

1975), vacated, 425 U.S. 947, 96 S. Ct. 1721 (1976). Now that Appellees have brought that 

case to the attention of the Court, Judge Wood would call attention to the helpful analysis of 

illegal vote dilution in that opinion. 

The Wallace court expressly approved the application of a balancing test in vote dilution 

cases and defined illegal vote dilution as a "substantial impairment of minority voting rights" 

resulting from some "fundamental unfairness in the electoral system," a definition which it 

traced to Whitcomb v. Chavis, 403 U.S. 124, 91 S. Ct. 1858 (1971) and White v. Regester, 

412 U.S. 755, 93 S. Ct. 2332 (1972). Wallace, 515 F.2d at 629, 633. The Wallace court 

emphasized that 

we have consistently adhered to the proposition that access to the political process 
and not population [is] the barometer of dilution of minority voting strength. 

Wallace, 515 F.2d at 630 (quoting Bradas v. Rapides Parish Police Jury, 508 F.2d 1109, 1112 

(Sth Cir. 1975) (emphasis added)). Zimmer v. McKeithen, 485 F.2d 1297 (Sth Cir. 1973), aff'd 

sub nom East Carroll Parish v. Marshall, 424 U.S. 636 (1976), on which Appellees also rely, 

likewise holds that access to the political process and not population is the "barometer of 

dilution" of minority voting strength. 485 F.2d at 1303. Like Wallace, Zimmer expressly 

attributes that proposition to Whitcomb, 403 U.S. at 149-50, and White, 412 U.S. at 765. 

II. APPELLEES MISCONSTRUE THE LINKAGE BETWEEN TEXAS STATE DISTRICT 
JUDGES’ ELECTORAL DISTRICTS AND THEIR JURISDICTION. 

In the appellate opinions in this case, the Fifth Circuit and the Supreme Court have 

properly used the concept of jurisdiction. Essentially, Appellees confuse the power of a judge 

  

§ 2 of the Voting Rights Act. This is a legal question which requires no further evidence. 

5 

 



to act, which is at issue, with subject matter jurisdiction, which is not at issue. As far as the 

latter goes, Texas state district judges do not merely have state-wide subject matter jurisdiction, 

as Appellees’ claim, they have world-wide subject matter jurisdiction. Alfaro v. Dow Chemical, 

751 S.W.2d 208, 211 (Tex. App. — Houston [1st Dist.] 1988), aff’d 786 S.W.2d 674 (Tex. 

1990). But this fact does not allow Texas state district judges to hear and decide cases 

world-wide — which is the real issue. 

The Texas Supreme Court long ago delineated very clearly its understanding of 

jurisdiction 

Section 1, article 5, of the Constitution states in what "magistracy” the judicial 
power shall be vested. It declares: "The judicial power of this State shall be 
vested in one Supreme Court, in Courts of Civil Appeals, in a Court of Criminal 
Appeals, in District Courts, in County Courts, in Commissioners Courts, in 
Courts of Justices of the Peace, and in such other courts as may be provided by 
law." The Constitution has thus erected a system of trial and appellate courts 
quite similar to that of the United States and those of the American states 
generally, all of which are an outgrowth of the judicial system of England, out 
of which the common law grew and attained its renown. 

The Constitution is specific in confiding trial jurisdiction to the district and county 
courts, and other inferior courts. State Constitution, article 5, §§ 8, 16, 19. 
These provisions mean that those courts are to exercise that portion of the judicial 
power allocated to them unimpeded by the supervision of any other tribunal, 
except in so far as powers of revision may be confided to other tribunals. The 
jurisdiction of these trial or inferior courts, without any exception, embraces the 
"power to hear and determine the matter in controversy according to established 
rules of law, and to carry the sentence or judgment of the court into execution.” 
11 Texas Jurisprudence, p. 711. § 9; Cleveland v. Ward, 116 Tex. 1, 285 S.W. 
1063. 

Morrow v. Corbin, 62 S.W.2d 641 (Tex. 1933) (emphasis in original). 

Texas law consistently and at all levels confines the power of a judge to the district 

whose citizens elected him. The Texas Supreme Court has appellate jurisdiction coextensive  



    

with the limits of the state. TEX. Gov’T CODE § 22.001. Correspondingly, Texas Supreme 

Court Justices are elected by all the voters of the State. TEX. CONST. ART. V § 2. Each Texas 

Court of Appeals "has civil appellate jurisdiction of all civil cases within its district." TEX. 

Gov’'T CoDE § 22.220. Likewise, its members are elected from the entire district. TEX. 

CONST. ART. V § 6. Finally, the county-wide jurisdiction of each Texas district court is 

provided by Article V § 8 of the Texas Constitution, and district judges are elected by the entire 

county. 

The linkage between county-wide jurisdiction and electoral base is the keystone to the 

entire structure of the administration of Texas trial courts. A state district judge has the power 

to act only in the county in which he is elected and over those cases properly docketed in that 

county. Therefore, a judge cannot try a Harris County divorce in Galveston County or even 

grant a default judgment in Galveston County. TEX. GOV'T CODE ANN. ART. 74.094(a) (West 

1991). Similarly, if a prisoner whose indictment was brought in Fort Bend County wants to 

enter a plea, and the prisoner is in jail in Harris County, where there are elected judges, a 

district attorney, and court reporters, the prisoner must nevertheless be taken to Fort Bend 

County to plead his case before a judge elected in Fort Bend County. No Harris County district 

judge has power to hear his plea. TEX. CRIM. PROC. CODE ANN. ART. 4.16 (West 1977). 

While district court judges in Harris County may exchange cases within that county,’ 

Harris County judges may not freely exchange benches or cases with other state district court 

judges elected in other counties by other voters. J udges can exchange benches with judges from 

other counties only on specific orders of the administrative judges of the judicial administrative 

  

3 See TEX. R. CIv. P. 330. 

 



    

region involved — and then only for a carefully circumscribed, stated purpose such as for a 

limited period of time* or for a single case. TEX. GOV'T CODE ANN. ART. 74.056 (West 

1988). If the judge enters orders or judgments outside the scope of the limited power to act 

conferred on him, his action is void. For example, the Judge of the 127th Judicial District Court 

of Harris County, Texas (Judge Wood) can exercise power for any district court in Harris 

County. But she can act outside of Harris County only on written order of the Administrative 

Judge of the Second Administrative Judicial Region, Judge Stovall (a Defendant in this case) or 

of the Chief Justice of the Texas Supreme Court, Chief Justice Phillips (also a Defendant). TEX. 

GOV'T CODE ANN. ART. 74.056 (West 1988). She can act in Bexar County only on order of 

the Administrative Judge for that region, Judge Cornyn (likewise a Defendant in this case). 

TEX. GOV'T CODE ANN. ART. 74.057 (West 1988). 

Appellees also illustrate their claim that Texas is really not interested in linking 

jurisdiction and electoral base by reference to justice of the peace courts. They argue that 

Justices of the peace are elected only from a precinct but have county-wide "jurisdiction." See, 

e.g., HLA’s Brief at 16. This is a misleading simplification of a complex truth. First, justices 

of the peace have very limited subject matter jurisdiction. They can hear cases only with an 

amount in controversy under $5,000. TEX. GOV'T CODE ANN. ART. 27.031. Even so, they are 

denied jurisdiction over many cases within that dollar limit, such as divorces and title to land 

and slander cases. Id. Typically, parties who appear before a justice of the peace are not 

represented by lawyers. Even more importantly, a justice of the peace need not be an attorney 

  

* A judge cannot be assigned to a bench outside of the county in which he was elected for 
more than ten (10) days without the agreement of the sitting judge. TEX. GOV'T CODE ANN 
ART. 74.060(a) (West Supp. 1991). 

 



    

himself; and, in a jury trial in justice court, the jury determines all questions of fact and law. 

TEX. R. CIv. P. 554. Moreover, there is a trial de novo in county court on all cases appealed 

from justice court. TEX. CIV. PRAC. & REM. CODE ANN. § 51.001 (West 1986); TEX. R. CIV. 

P. 574b. 

Finally, the only cases over which justices of the peace have exclusive jurisdiction are 

forcible entry and detainer cases; and, significantly, a justice of the peace has jurisdiction over 

these serious matters only within the limits of his own precinct. TEX. CIV. PRAC. & REM. 

CODE § 15.084. 

The linkage between electoral district and the power to act with ultimate authority, which 

Texas has historically insisted upon, is therefore retained with respect to all Texas state courts. 

CONCLUSION 

The essential issue this Court must decide is whether Appellees have pled and proved a 

violation of § 2 of the Voting Rights Act for which relief can be granted. Appellees have not 

addressed the issues of first impression framed for this Court by the Supreme Court. 

Specifically, the Supreme Court asked this Court to assess the proper weight to be assigned a 

state’s interest in maintaining its judicial electoral system for the purpose of whether there has 

been a violation of § 2 and, if so, whether the unintentional dilution of the votes of protected 

minorities in single-member officeholder elections can be remedied under § 2. Judicial 

subdistricting would violate Texas’ fundamental state interest in linking a trial judge’s electoral 

base with the jurisdiction of his court. Appellees have failed, as a matter of law, to prove that 

Texas’ system for electing state district judges results in illegal vote dilution. 

 



    

For the foregoing reasons, the trial court’s decision, holding that Texas’ state district 

judge election system results in illegal vote dilution in all challenged district judge districts, is 

fundamentally erroneous. The Court should reverse the decision of the district court and render 

judgment for Defendants/Appellants. 

Respectfully submitted, 

PORTER & CLEMENTS 

: 5 vo 

1/ Eugene ‘Clements Z 
‘Evelyn V. Keyes 
3500 NCNB Center 
P.O. Box 4744 

Houston, Texas 77210-4744 

Phone: (713) 226-0600 

Fax: (713) 228-1331 

  

ATTORNEYS FOR DEFENDANT/ 

APPELLANT JUDGE WOOD 

CERTIFICATE OF SERVICE 
  

I hereby certify that on this 24th day of October, 1991, a true and correct copy of the 
above and foregoing document has been mailed to all counsel of record by first class United 
States mail, postage prepaid, addressed as follows: 

Mr. Michael J. Wood 

Attorney at Law 

440 Louisiana, Suite 200 

Houston, Texas 77002 

10 

 



Mr. David C. Godbey, Jr. 
Mr. Robert H. Mow, Jr. 

Hughes & Luce 

2800 Momentum Place 

1717 Main Street 

Dallas, Texas 75201 

Mr. John L. Hill, Jr. 
Mr. Andy Taylor 
Liddell, Sapp, Zivley, Hill & Laboon 
3300 Texas Tower 

Houston, Texas 77002 

Mr. Seagal V. Wheatley 

Mr. Donald R. Philbin, Jr. 
Oppenheimer, Rosenberg, Kelleher & Wheatley 
711 Navarro Street, 6th Floor 

San Antonio, Texas 78205 

Mr. Mark H. Dettman 

Attorney at Law 

Post Office Bax 2559 

Midland, Texas 79702 

Mr. Gerald H. Goldstein 

Goldstein, Goldstein & Hilley 

29th Floor, Tower Life Bldg. 

San Antonio, Texas 78205 

Mr. Joel H. Pullen 

Kaufman, Becker, Pullen & Reibach 
2300 NCNB Plaza 

300 Convent Street 

San Antonio, Texas 78205 

Mr. R. James George 

Mr. John M. Harmon 

Ms. Margaret H. Taylor 

Graves, Dougherty, et al. 

P. O. Box 98 

Austin, Texas 78767  



Mr. William L. Garrett 
Garrett, Thompson & Chang 

8300 Douglas, #800 

Dallas, Texas 75225 

Mr. Rolando L. Rios 

Ms. Susan Finkelstein 
Attorneys at Law 
201 N. St. Mary’s St., #521 
San Antonio, Texas 78250 

Ms. Gabrielle K. McDonald 
Matthews & Branscomb 

301 Congress Ave., #2050 

Austin, Texas 78701 

Mr. Renea Hicks 

Mr. Javier Guajardo 
Special Asst. Atty. Generals 
P. O. Box 12548 

Capitol Station 

Austin, Texas 78711 

Mr. Edward B. Cloutman, II 

Mullinas, Wells, Baab & Cloutman 
3301 Elm Street 

Dallas, Texas 75226-1637 

Ms. Sherrilyn A. Ifill 
NAACP Legal Defense and 
Education Fund, Inc. 

99 Hudson Street, 16th Floor 
New York, New York 10013 

Mr. E. Brice Cunningham 
Attorney at Law 
777 South R. L. Thornton Frwy., Suite 121 
Dallas, Texas 75203 

Mr. Michael Ramsey 
Ramsey & Tyson 
2120 Welch 

Houston, Texas 77019  



    

Mr. Daniel J. Popeo 
Mr. Paul D. Kamenar 

Mr. Alan M. Slobodin 
1705 N. Street, N.W. 

Washington, D.C. 20036 

Mr. Paul Strohl 

Attorney at Law 

100 Founders Square 
900 Jackson Street 

Dallas, Texas 75202 

Mr. Daniel M. Ogden 
Attorney at Law 

900 Chateau Plaza 

2515 McKinney Avenue 
Dallas, Texas 75201 

  

. KEYES 
= A J Cnn 

EVELYN ¥. 

3285C:\DOCS\W0027001\051 

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