CareFlite v. Rural Hill Emergency Medical Services, Inc., 418 S.W.3d 132

CareFlite sought a writ of mandamus to compel Rural Hill to disclose information under the Texas Public Information Act (TPIA).
Rural Hill, a not-for-profit EMS provider in Hill County, argued it is not a governmental body under the TPIA and counterclaimed under the UDJA for attorney’s fees and declaratory relief.
Each side moved for traditional summary judgment; the trial court granted Rural Hill's motion and denied CareFlite’s.
The trial court severed the summary judgment portion from a second, unrelated suit and rendered a final order on the first suit.
The court analyzed whether Rural Hill’s funding and contractual structure with two cities created an arms-length relationship and/or governmental body status.
Key issue is whether Rural Hill’s receipt of public funds and its contract framework make it a governmental body subject to the TPIA.

Issue	Plaintiff's Argument	Defendant's Argument	Held
UDJA counterclaim and attorney’s fees	CareFlite failed to justify UDJA defenses	Rural Hill’s UDJA counterclaim sought broader declaratory relief and fees	Trial court’s UDJA ruling affirmed; fees awarded
Is Rural Hill a governmental body under the TPIA	Rural Hill is supported by public funds and shares common purpose with cities	Contracts with cities constitute arms-length arrangements; Rural Hill not a governmental body	Rural Hill is not a governmental body; not subject to TPIA

Kneeland v. National Collegiate Athletic Association, 850 F.2d 224 (5th Cir. 1988) (analyze patterns of public-fund support to determine governmental status)
City of Houston v. Clear Creek Basin Auth., 589 S.W.2d 671 (Tex. 1979) (summary judgment standard and burden-shifting framework)
American Tobacco Co. v. Grinnell, 951 S.W.2d 420 (Tex. 1997) (summary judgment criteria for affirmative defenses and elements)
Sci. Spectrum, Inc. v. Martinez, 941 S.W.2d 910 (Tex. 1997) (summary judgment proof and evidentiary standards)