Texas Department of Transportation// Texas Weekly Advocate and Dr. Jeffrey White v. Texas Weekly Advocate and Dr. Jeffrey White// Cross-Appellee, Texas Department of Transportation
The Texas Department of Transportation (TxDOT) amended its crash report form, removing a space for driver telephone numbers. Texas Weekly Advocate and Dr. Jeffrey White (Plaintiffs) sued TxDOT under the Administrative Procedure Act (APA) and the Uniform Declaratory Judgments Act (UDJA), arguing that TxDOT failed to comply with proper rulemaking procedures. The trial court granted summary judgment for Plaintiffs on their APA claim, enjoining TxDOT, but dismissed the UDJA claim and denied attorney's fees. On appeal, the court vacated the trial court's APA injunction and dismissed that part of the cause as moot, as TxDOT had subsequently completed the required rulemaking process. Additionally, the Plaintiffs' UDJA claim was deemed moot due to redundancy with the APA claim, and the appellate court affirmed the trial court's denial of attorney's fees, finding no abuse of discretion as the UDJA claim did not substantially broaden the action already provided by the APA.