The University of Texas at Austin and Jay Hartzell, in His Official Capacity as Interim President of the University of Texas at Austin v. Gatehouse Media Texas Holdings II, Inc., D/B/A Austin American-Statesman

Supreme Court of Texas
══════════
No. 23-0023
══════════

The University of Texas at Austin and Jay Hartzell, in His
Official Capacity as Interim President
of the University of Texas at Austin,
Petitioners,

v.

GateHouse Media Texas Holdings II, Inc.,
d/b/a Austin American–Statesman,
Respondent

═══════════════════════════════════════
On Petition for Review from the
Court of Appeals for the Eighth District of Texas
═══════════════════════════════════════

Argued October 1, 2024

CHIEF JUSTICE HECHT delivered the opinion of the Court.

In this case the federal Family Educational Rights and Privacy
Act of 1974 (FERPA) and Texas’ Public Information Act (PIA) intersect.
The Austin American–Statesman1 requested that the University of
Texas at Austin disclose the final results of disciplinary hearings

1 The Statesman’s parent company is respondent GateHouse Media
Texas Holdings II.
involving sex offenses. The University refused to produce the
information without requesting a decision of the Office of the Attorney
General (OAG). We hold that the PIA authorized the University’s
refusal without an OAG opinion and, therefore, that the trial court
should have granted the University’s motion for summary judgment. We
reverse the court of appeals’ judgment 2 and render judgment for the
University.
I
A
FERPA protects student privacy by conditioning the receipt of
federal funds on an educational institution’s compliance with certain
requirements. 3 As relevant here, the act prohibits federal funding of a
university with “a policy or practice of permitting the release of
education records” without the student’s consent. 4 “Education records”
are broadly defined as “those records, files, documents, and other
materials” that “contain information directly related to a student” and
“are maintained by an educational agency or institution”. 5 The term

2 656 S.W.3d 791 (Tex. App.—El Paso 2022).

3 See 20 U.S.C. § 1232g.

4 Id. § 1232g(b)(1). The statute makes an exception for several
categories of individuals and entities to whom disclosure without consent is
permitted; they include other school officials and certain federal, state, or local
government officials. See id. § 1232g(b)(1)(A)-(L).
5 Id. § 1232g(a)(4)(A). The term “does not include” certain records
enumerated in Section 1232g(a)(4)(B) such as “records maintained by a law
enforcement unit of the educational agency or institution that were created by
that law enforcement unit for the purpose of law enforcement”. Id.
§ 1232g(a)(4)(B)(ii). None of the exclusions apply here.

2
includes disciplinary records, 6 but the act makes exceptions to the
general rule prohibiting their disclosure. Section 1232g(b)(6)(B)
authorizes a university to disclose to a third person the final results of
a disciplinary proceeding arising from an allegation that a student
committed a crime of violence or nonforcible sex offense if the university
determines that the allegation has merit:
Nothing in this section shall be construed to prohibit an
institution of postsecondary education from disclosing the
final results of any disciplinary proceeding conducted by
such institution against a student who is an alleged
perpetrator of any crime of violence . . . or a nonforcible sex
offense, if the institution determines as a result of that
disciplinary proceeding that the student committed a
violation of the institution’s rules or policies with respect
to such crime or offense. 7
If an institution chooses to disclose the final results of a
disciplinary proceeding in accordance with this exception, those results
“shall include only the name of the student, the violation committed, and
any sanction imposed by the institution on that student”. 8 The results
“may include the name of any other student, such as a victim or witness,
only with the written consent of that other student.” 9

6 See id. § 1232g(h)(1).

7 Id. § 1232g(b)(6)(B).

8 Id. § 1232g(b)(6)(C)(i).

9 Id. § 1232g(b)(6)(C)(ii).

3
B
1
Texas’ PIA reflects “the policy of this state” that the public “is
entitled, unless otherwise expressly provided by law, at all times to
complete information about the affairs of government and the official
acts of public officials and employees.” 10 The act states that it “shall be
liberally construed in favor of granting a request for information.” 11
Subchapter B provides the general rule of disclosure. Under
Section 552.021, “[p]ublic information is available to the public at a
minimum during the normal business hours of the governmental
body.” 12 Public information is “information that is written, produced,
collected, assembled, or maintained under a law or ordinance or in
connection with the transaction of official business” 13 but does not
include information “made confidential under this chapter or other
law.” 14 Subchapter B expressly recognizes FERPA’s primacy;
Section 552.026 provides that the PIA “does not require the release of
information contained in education records of an educational agency or
institution, except in conformity with [FERPA].” 15

10 TEX. GOV’T CODE § 552.001(a).

11 Id. § 552.001(b).

12 Id. § 552.021; see also id. § 552.221(a) (“An officer for public
information of a governmental body shall promptly produce public information
for inspection, duplication, or both on application by any person to the officer.”).
13 Id. § 552.002(a).

14 Id. § 552.022(a).

15 Id. § 552.026.

4
2
The PIA makes exceptions to the general rule of disclosure in
Section 552.021, and many are in Subchapter C. The Legislature,
through the PIA or other law, has designated certain kinds of
information to be “confidential”. 16 Confidential information must not be
disclosed. Under Section 552.101, “[i]nformation is excepted from the
requirements of Section 552.021 if it is information considered to be
confidential by law, either constitutional, statutory, or by judicial
decision.” 17 Moreover, the act makes it a misdemeanor crime—
punishable by fine, confinement, or both—to “distribute[] information
considered confidential under the terms of [the PIA].” 18 An example of
information made confidential by the PIA is a “sensitive crime scene
image in the custody of a governmental body”. 19 The act makes such an
image “confidential and excepted from the requirements of
Section 552.021” while enumerating certain persons, such as “the
deceased person’s next of kin”, who are permitted to view the image. 20
The PIA excepts other kinds of information from disclosure
without making the information confidential. 21 The Legislature has

16 See Tex. Comptroller of Pub. Accts. v. Att’y Gen. of Tex., 354 S.W.3d

336, 359 (Tex. 2010) (Wainwright, J., dissenting).
17TEX. GOV’T CODE § 552.101. However, the act authorizes a
governmental body to release confidential information about a person to that
person or the person’s representative. Id. § 552.023(a).
18 Id. § 552.352(a), (b).

19 Id. § 552.1085(c).

20 Id. § 552.1085(c), (d).

21 See Comptroller, 354 S.W.3d at 359-360 (Wainwright, J., dissenting).

5
given the governmental body discretion to disclose information in this
category even though disclosure is not required. Section 552.007 states
that the PIA “does not prohibit a governmental body . . . from voluntarily
making part or all of its information available to the public, unless the
disclosure is expressly prohibited by law or the information is
confidential under law.” 22 Thus, the PIA “creates three distinct
categories of public information—information required to be disclosed,
information excepted from mandatory (but not voluntary) disclosure,
and confidential information that is prohibited from disclosure and
subject to criminal penalties.” 23
3
Subchapter C includes an exception for student records in
Section 552.114. The section is titled, “Exception: Confidentiality of
Student Records.” Subsection (a) defines a student record to include an
education record under FERPA. 24 Subsection (b) contains two sentences.
The first makes information in a student record at a state-funded
educational institution “confidential and excepted from the
requirements of Section 552.021”. 25 The second sentence states that

22 TEX. GOV’T CODE § 552.007(a).

23 Comptroller, 354 S.W.3d at 360 (Wainwright, J., dissenting).

24 TEX. GOV’T CODE § 552.114(a)(1). The definition also includes
“information in a record of an applicant for admission to an educational
institution, including a transfer applicant.” Id. § 552.114(a)(2).
25 Id. § 552.114(b).

6
“[t]his subsection does not prohibit the disclosure” of a student record if
it “is authorized by [FERPA] or other federal law.” 26
Subsection (c) clarifies that “[a] record covered by Subsection (b)
shall be made available on the request of” three categories of people:
“(1) educational institution personnel; (2) the student involved or the
student’s parent, legal guardian, or spouse; or (3) a person conducting a
child abuse investigation” under the Family Code. 27 Subsection (d),
which we discuss below, addresses the institution’s authority to “redact
information covered under Subsection (b)”. 28 Subsection (e) specifies
that “[i]f an applicant for admission to an educational institution
described by Subsection (b)”—or a parent or guardian of a minor
applicant—“requests information in the record of the applicant, the
educational institution shall disclose any information” related to the
applicant’s application that was provided to the institution by the
applicant. 29
4
There is a hoop a governmental body potentially must jump
through before withholding information as excepted from the general
rule of disclosure. Under Section 552.301, if a governmental body
“wishes to withhold [information] from public disclosure” and “considers
[the information] to be within one of the exceptions under
Subchapter C”, the body “must ask for a decision from the attorney

26 Id. (emphasis added).

27 Id. § 552.114(c).

28 Id. § 552.114(d).

29 Id. § 552.114(e).

7
general about whether the information is within that exception”. 30 But
it must do so only “if there has not been a previous determination about
whether the information falls within one of the exceptions.” 31 And there
is at least one more caveat: under Section 552.114(d), and “[e]xcept as
provided by Subsection (e)” of that provision, “an educational institution
may redact information covered under Subsection (b) from information
disclosed under Section 552.021 without requesting a decision from the
attorney general.” 32
When an OAG decision is required, the governmental body “must
ask for the attorney general’s decision and state the exceptions that
apply within a reasonable time but not later than the 10th business day
after the date of receiving the written request.” 33 There are additional
statutory requirements related to the governmental body’s request for
an OAG decision. 34 Under Section 552.302, “[i]f a governmental body
does not request an attorney general decision as provided by
Section 552.301” and does not comply with other requirements of that
section, “the information requested in writing is presumed to be subject
to required public disclosure and must be released unless there is a
compelling reason to withhold the information.” 35

30 Id. § 552.301(a).

31 Id.

32 Id. § 552.114(d).

33 Id. § 552.301(b).

34 See id. § 552.301(d)-(g).

35 Id. § 552.302.

8
5
The PIA provides a mechanism to have a dispute over its
provisions settled in court. In Section 552.321, the act authorizes “[a]
requestor or the attorney general” to “file suit for a writ of mandamus
compelling a governmental body to make information available for
public inspection if the governmental body refuses to request an
attorney general’s decision . . . or refuses to supply public information or
information that the attorney general has determined is public
information that is not excepted from disclosure”. 36 “A suit filed by a
requestor . . . must be filed in a district court for the county in which the
main offices of the governmental body are located.” 37
II
A
On August 30, 2019, the executive editor of the Statesman
emailed University President Gregory Fenves and Senior Vice
President–Chief Financial Officer Darrell Bazzell a request for the “final
results” of certain disciplinary hearings conducted by the University
since 2014. Quoting FERPA Section 1232g(b)(6)(B)-(C), the request
sought the results of hearings involving any student “in which it was
determined that the student is either ‘an alleged perpetrator of a crime
of violence,’ including forcible sex offenses, or ‘an alleged perpetrator of
a nonforcible sex offense,’” and in which the University determined that
the student violated its rules or policies:
This is a request under the Texas Public Information Act

36 Id. § 552.321(a).

37 Id. § 552.321(b).

9
for disclosure of public records. It is made on behalf of the
Austin American–Statesman newspaper and its parent
company, GateHouse Media.
This request seeks “final results” of all disciplinary
hearings conducted by your institution into any student
since Jan. 1, 2014, in which it was determined that the
student is either “an alleged perpetrator of a crime of
violence,” including forcible sex offenses, or “an alleged
perpetrator of a nonforcible sex offense,” and with respect
to the allegation made against him or her, the student has
committed a violation of your institution’s rules or policies.
The “final results” should include only:
• The name of the student;
• The violation committed, meaning the institutional
rules or code sections that were violated and any
essential findings supporting the institution’s
conclusion that the violation was committed; and
• Any sanction imposed by your institution against the
student, meaning a description of the disciplinary
action taken by the institution, the date of its
imposition, and its duration.
Disclosure of these records furthers the public interest and
is important for our newsgathering. As such, we request
that they be made available promptly . . . .
More than two weeks later, on September 16, 2019, the
University’s open records coordinator responded by email that FERPA
does not require disclosure of the records requested and that the
University was declining to provide them:
This email is provided in final response to your below
request to The University of Texas at Austin. The Family
Educational Rights and Privacy Act of 1974 (FERPA), 20
U.S.C. § 1232g, does not require The University to disclose
any student information that is responsive to your request,
and we decline to do so. Thank you.

10
The University did not request an OAG decision before
responding. 38
B
The Statesman sued the University under Section 552.321,
seeking a writ of mandamus compelling the University to provide the
records requested. Both sides filed traditional motions for summary
judgment. The trial court granted the Statesman’s motion and denied
the University’s. In a letter to the parties, the court reasoned that the
University was required to seek an OAG decision and that its failure to
do so raised the presumption that the information is subject to
disclosure absent a compelling reason to withhold it. The court found no
compelling reason for the University to withhold the records.
The Statesman filed a motion for attorney fees under PIA
Section 552.323(a), which requires the court to “assess costs of litigation
and reasonable attorney fees incurred by a plaintiff who substantially
prevails” unless “the court finds that the governmental body acted in
reasonable reliance on” a court order or attorney general decision. 39 The
court declined that request, concluding that the University relied on a
plausible interpretation of the PIA, and rendered a final judgment.
A divided court of appeals affirmed the part of the judgment
requiring the University to produce the requested information. 40 The
majority held that under Section 552.302, the University did not

38 The University requested an OAG decision months later while
litigation was already pending. We address OAG’s response in Part IV.
39 TEX. GOV’T CODE § 552.323(a).

40 656 S.W.3d 791.

11
establish a “compelling reason” for withholding the requested
information in the face of its failure to request an OAG decision. 41 This
holding was based on its conclusion that Section 552.114(b) does not give
the University discretion to withhold the requested records. The
majority recognized that the section’s “first sentence, if it was standing
alone, would create a complete prohibition on disclosing any information
within a student record.” 42 But the majority read the second sentence as
“an exception to the exception provided in the first sentence” 43 and
reflective of the Legislature’s intent “to clarify that the exception or
prohibition does not apply to information authorized for disclosure by
FERPA or other federal law.” 44 The majority opined that construing
Section 552.114(b) this way is consistent with the PIA’s policy statement
that the act should be liberally construed in accordance with “the PIA’s
underlying purpose”. 45
The majority went on to hold that the trial court abused its
discretion by denying the Statesman’s request for attorney fees,
reversed that part of the trial court’s judgment, and remanded. 46 The
only reference to Section 552.026 in its opinion is in a citation to several
PIA provisions that “provide explicit exceptions to the disclosure

41 See id. at 803-806.

42 Id. at 805.

43 Id. at 804.

44 Id. at 805.

45 Id.

46 Id. at 808.

12
requirement.” 47 The majority did not analyze the section’s applicability
to this case.
Justice Alley dissented. He recognized that “the PIA contains two
sections addressing the confidentiality of student records,”
Section 552.026 and Section 552.114. 48 He acknowledged that “neither
section expressly addresses whether final-results information is subject
to mandatory release or not.” 49 But after working through the language
of each section, he concluded that neither section requires release of the
information requested by the Statesman.
Justice Alley pointed to the language in Section 552.026
providing that the PIA does not require release of education records
“except in conformity with [FERPA].” Citing to a dictionary definition of
conformity, he reasoned that “[b]y requiring ‘conformity’ with FERPA,
this section of the PIA only requires a state funded educational
institution to release information in a student’s educational record when
FERPA correspondingly requires its release—such as when the
information is requested by a parent.” 50 “[B]ecause FERPA does not
require the release of final-results information to third parties,” he
concluded, “neither does section 552.026 require its release.” 51
Turning to Section 552.114, Justice Alley noted that
subsection (b)’s first sentence makes education records “confidential and

47 Id. at 799.

48 Id. at 810 (Alley, J., dissenting).

49 Id. (Alley, J., dissenting).

50 Id. (Alley, J., dissenting).

51 Id. at 811 (Alley, J., dissenting).

13
excepted from the requirements of Section 552.021”. 52 Section 552.114,
through subsections (c) and (e), “sets forth only four situations in which
disclosure is required”: a request made by an educational institution, by
a student or the student’s parent or spouse, by a person conducting a
child-abuse investigation, and by an applicant for admission. 53
Justice Alley characterized the second sentence of subsection (b)
as “a catch-all provision . . . that mimics the permissive language used
in FERPA for information requested by other individuals or entities not
in the above list.” 54 Noting its “does not prohibit” language, he reasoned
that just as FERPA authorizes but does not require the release of final-
results information, “section 552.114(b) also simply gives an educational
institution the discretion to release final-results information in redacted
form.” 55 He added:
Had the legislature intended to require the release of such
information, it knew how to do so, as it used mandatory
language when requiring the release of information to
certain specified categories of requestors, and it could have
easily included a section requiring the mandatory release
of final-results information as well, but chose not to. 56
Justice Alley went on to consider whether the University was
required to seek an OAG decision. He opined that it was not because
OAG has previously determined “that an OAG decision is unnecessary

52 Id. (Alley, J., dissenting) (quoting TEX. GOV’T CODE § 552.114(b)).

53 Id. (Alley, J., dissenting).

54 Id. (Alley, J., dissenting).

55 Id. (Alley, J., dissenting).

56 Id. at 811 n.2 (Alley, J., dissenting).

14
when an educational institution decides to withhold educational records
protected by FERPA.” 57 We granted the University’s petition for review.
III
We start by examining whether the PIA requires the University
to disclose the final-results records requested by the Statesman. The
parties have focused their arguments on Section 552.114(b). They agree
that its first sentence, standing alone, makes information in a
disciplinary record confidential and excepted from disclosure. But they
dispute the effect of its second sentence: “This subsection does not
prohibit the disclosure or provision of information included in an
education record if the disclosure or provision is authorized by
[FERPA]”. 58 The Statesman urges the interpretation adopted by the
court of appeals’ majority: this second sentence negates the first one
with respect to any information that FERPA authorizes to be disclosed,
with the result that disclosure of such information is required under
Section 552.021. The University argues that “does not prohibit
disclosure” cannot mean “requires disclosure”.
We need not determine the exact meaning of Section 552.114(b)
here. As we frequently explain, statutory text must always be read in
the context and framework of the entire statute. 59 The context and

57 Id. at 812 (Alley, J., dissenting).

58 TEX. GOV’T CODE § 552.114(b).

59 See, e.g., Pub. Util. Comm’n of Tex. v. Luminant Energy Co., 691
S.W.3d 448, 460 (Tex. 2024) (“We discern a statute’s objectives from its plain
text. That text must always be read in context—not isolation. We give meaning
to every word in a statute, harmonizing each provision, while considering the

15
framework of the PIA includes Section 552.026, which states that “[t]his
chapter”—meaning the entire PIA, which includes Sections 552.021
and 552.114—“does not require the release of information contained in
education records of an educational agency or institution, except in
conformity with [FERPA].” 60 Whatever Section 552.114(b) means
precisely, it cannot be read to conflict with Section 552.026.
The Statesman argues that “except in conformity with” means
“except where release is allowed by FERPA”, so Section 552.026 imposes
a disclosure obligation in this case. This argument fails the
plain-language test. “In conformity with” means in harmony,
agreement, or congruity with. 61 Because FERPA’s
Section 1232g(b)(6)(B) permits but does not require disclosure of the
information, the University may elect to disclose it or withhold it, and
either choice will be “in conformity with” FERPA. As a result,
Chapter 552 (including Sections 552.021 and 552.114) “does not require
the release of [the] information”. 62 We agree with the court of appeals’
dissent on this point.
Finally, and echoing the court of appeals’ majority, the Statesman
argues that the PIA’s “general purpose” and its opening statement that
the act should be “liberally construed in favor of granting a request for

context and framework of the entire statute, in order to meld its words into a
cohesive reflection of legislative intent.” (cleaned up)).
60 TEX. GOV’T CODE § 552.026 (emphasis added).

61 Conformity, WEBSTER’S THIRD NEW INTERNATIONAL DICTIONARY
(1966).
62 See TEX. GOV’T CODE § 552.026.

16
information” 63 require the interpretation it urges. We disagree. Neither
the PIA’s purpose nor its directive that the act be liberally construed in
favor of disclosure overcomes the courts’ obligation to construe statutory
text by its plain language. 64
We hold that Section 552.026 grants an educational institution
discretion whether to disclose information in an education record if the
disclosure is authorized by FERPA. The court of appeals thus erred by
construing the PIA to require mandatory disclosure of such information.
IV
The remaining issue is whether disclosure is nonetheless required
because the University did not timely seek an OAG decision under
Section 552.301(a). As we noted earlier, this section requires an OAG
decision only if the governmental body “considers [the information
requested] to be within one of the exceptions under Subchapter C”. 65
Section 552.026 is in Subchapter B, not Subchapter C. So
Section 552.301(a) does not apply.
There are other statutory clues that an OAG decision is not
required here. If Section 552.114(b) authorizes the University to
withhold the requested information, as it argues and the court of
appeals’ dissent concluded, then the redaction provision in
Section 552.114(d) may negate the obligation to seek an OAG decision

63 Id. § 552.001(b).

64 See ANTONIN SCALIA & BRYAN A. GARNER, READING LAW: THE
INTERPRETATION OF LEGAL TEXTS 35 (2012) (“While such provisions as a
preamble or purpose clause can clarify an ambiguous text, they cannot expand
it beyond its permissible meaning.”).
65 TEX. GOV’T CODE § 552.301(a).

17
before withholding documents under Section 552.114(b). It states that
“an educational institution may redact information covered under
Subsection (b) from information disclosed under Section 552.021
without requesting a decision from the attorney general.” 66 The
University reasons that any production it would make to the Statesman
would consist of pages of black bars without any text and that producing
pages of black bars to the Statesman without seeking an OAG decision
is the same as producing nothing without seeking an OAG decision.
The Statesman responds that the dictionary definition of
“redact” 67 and the statute’s inclusion of the words “from information
disclosed under Section 552.021” 68 presuppose that some records are
being produced under the general rule. If none are, the Statesman
argues, then subsection (d) does not apply, and an OAG decision must
be sought. Although the Statesman’s textual argument has intuitive
appeal, it does not work in the context of the entire statute.
Section 552.301(e) requires that a governmental body requesting
an OAG decision submit with its request certain information that OAG
needs to make its decision, including “a copy of the specific information
requested” or “representative samples of the information if a voluminous
amount of information was requested”. 69 But in a 2006 letter from the

66 Id. § 552.114(d).

67 Redaction, BLACK’S LAW DICTIONARY (11th ed. 2019) (“[t]he careful

editing of a document, esp. to remove confidential references or offensive
material”); see also 656 S.W.3d at 802 (providing dictionary definitions).
68 TEX. GOV’T CODE § 552.114(d).

69 Id. § 552.301(e)(1)(D); see also id. § 552.303.

18
U.S. Department of Education to OAG, the Department communicated
that “FERPA does not permit an educational agency or institution in
Texas to disclose, without parental consent, education records to the
OAG for the purpose of determining whether it has complied with the
PIA or whether it has redacted more than is necessary under FERPA.” 70
Since receiving that letter, OAG has refused to review education records
submitted under Section 552.301 without parental consent (or consent
of the student if over 18).
The University ultimately requested an OAG decision in March
2020, while litigation in the trial court was ongoing. OAG responded
that, in accordance with the Department’s 2006 letter, it would not
review unredacted education records—or even redacted education
records to determine whether the redactions comply with FERPA—and
that it would “not address your argument under [S]ection 552.114 of the
Government Code.” OAG continued: “Because the DOE has determined
that educational agencies and institutions are in the best position to
make determinations under FERPA, such agencies and institutions may
withhold from public disclosure personally identifiable information in
education records without the necessity of requesting an attorney
general decision.” This letter is consistent with OAG’s Public
Information Handbook, which explains that “the attorney general will
not address the applicability of FERPA to any records submitted as part
of a request for decision. Such determinations under FERPA must be

70 Letter to Texas Attorney General, U.S. DEP’T OF EDUC. 5 (July 25,

2006), https://www.texasattorneygeneral.gov/sites/default/files/files/divisions/
open-government/20060725-USDOE-FERPA.pdf.

19
made by the educational authority in possession of the education
records.” 71
These policy documents reflect that if the University had timely
requested an OAG decision on the Statesman’s request, OAG would not
have reviewed the submission. In these circumstances, we agree with
the University that Section 552.114(d) negates its obligation to seek an
OAG decision before withholding information under Section 552.114(b).
We hold that the University was not required to seek an OAG
decision before withholding the information requested by the
Statesman. 72
* * * * *
The University established its entitlement to judgment as a
matter of law. We reverse the court of appeals’ judgment and render
judgment for the University.

Nathan L. Hecht
Chief Justice

OPINION DELIVERED: December 31, 2024

71 Public Information Act Handbook 2018, OFF. OF THE ATT’Y GEN. OF

TEX. 119, https://www.texasattorneygeneral.gov/sites/default/files/files/
divisions/open-government/2018_Public-Information-Handbook.pdf.
72 Because we conclude that the University was not required to seek an

OAG decision under Section 552.301(a), we need not address whether it had a
compelling reason to withhold the documents under Section 552.302. Our
disposition also renders the University’s challenge to the court of appeals’
judgment on attorney fees inapposite.

20