Empower Texans, Inc. and Michael Quinn Sullivan v. Texas Ethics Commission
Appellants Empower Texans, Inc. and Michael Quinn Sullivan appealed a trial court's summary judgment regarding their counterclaim against the Texas Ethics Commission. They sought a declaratory judgment that Texas Government Code sections 571.061, .172, and .173 violate the Texas Constitution's Separation of Powers Clause, contending the Commission is a legislative body improperly exercising executive powers. The trial court affirmed the constitutionality of the statutes, ruling the Commission is an executive agency with constitutionally granted legislative powers. The Court of Appeals affirmed the trial court's judgment, concluding that neither the placement of the Commission's enabling provision in Article III nor its hybrid appointment procedure conclusively establishes it as a legislative body. Consequently, the appellate court found no violation of the Separation of Powers Clause.