Rowan v. Pickett

2 Citing cases

  1. Hays Co. v. Hays Co. Water Planning

    106 S.W.3d 349 (Tex. App. 2003)   Cited 31 times
    Holding that no Open Meetings violation was shown and explaining that "meeting must have occurred" in order to have Open Meetings violation and that it was not "uncommon for staff to speak with a commissioner for clarification in order to properly perform staff duties"

    Although some case law has been interpreted to deem commissioners courts subject to the "open courts" provision, the most often cited cases do not expressly state that proposition. See Rowan v. Pickett, 237 S.W.2d 734 (Tex.Civ.App.-San Antonio 1951, no writ); Swaim v. Montgomery, 154 S.W.2d 695 (Tex.Civ.App.-Amarillo 1941, writ ref'd w.o.m.); Tarrant County v. Smith, 81 S.W.2d 537 (Tex.Civ.App.-Fort Worth 1935, writ ref'd). Each of these cases held that commissioners cannot bind the county by their separate, individual action.

  2. Burns v. Harris County Bail Bond Bd.

    139 F.3d 513 (5th Cir. 1998)   Cited 155 times
    Holding that plaintiff lacked continuing property interest in expired bail bondsman's license: "The fact that Burns previously held a property license (which had expired some two years earlier) is insufficient to create a property interest entitled to due process protection in March 1995."

    The district court correctly determined that the separate actions of individual members of the Board are not sufficient to bind the Board as an entity. Bee County v. Roberts, 437 S.W.2d 62, 64 (Tex.Civ.App. — Corpus Christi 1968, no writ); Rowan v. Pickett, 237 S.W.2d 734, 738 (Tex.Civ.App.-San Antonio 1951, no writ). Pursuant to the Bail Bond Act, the Board can take action only when a quorum of four members is present. Bail Bond Act § 5(d).