Greater Houston Partnership v. Greg Abbott, Texas Attorney General And Jim Jenkins, 407 S.W.3d 776

GHP is a Texas nonprofit described as a regional chamber of commerce; its purposes include promoting economic growth and disseminating business information.
GHP’s budget is about $11.7 million, funded mainly by 2,100 member companies and some public funds for city/county economic development services.
Two contracts with the City of Houston (2007 and 2008) paid GHP roughly $1.67 million and $0.885 million respectively for economic development and marketing services related to the City and HAS.
Under these contracts, GHP had broad obligations to identify opportunities, conduct research, support HAS marketing, promote international outreach, coordinate with government bodies, and provide city-specific benefits.
In May 2008, Jim Jenkins, a member of the public, requested GHP’s 2007 check register showing payees, dates, and amounts; GHP denied applicability of the PIA and referred the matter to the AG.
The Attorney General’s Open Records Division ruled that GHP fell within the PIA’s definition of a governmental body, subject to disclosure.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether GHP is a governmental body under the PIA	GHP asserts no agency-like relationship and that public funds do not constitute support.	GHP’s receipt of public funds and common objectives with the City indicate a governmental body.	GHP is a governmental body under the PIA.
Whether the district court had jurisdiction given post-contract changes	Even if governmental during 2007–2008, later contract changes removed status; no ongoing government body.	Public information was created while GHP was a governmental body; PIA purpose is disclosure regardless of later status.	Information remains public information; court has jurisdiction to order disclosure.

Kneeland v. National Collegiate Athletic Assoc., 850 F.2d 224 (5th Cir. 1988) (framework for when private funds trigger PIA disclosure)
Texas Ass’n of Appraisal Dists., Inc. v. Hart, 382 S.W.3d 587 (Tex. App.-Austin 2012) (agency deference and ambiguity in PIA interpretation)
Abbott v. City of Corpus Christi, 109 S.W.3d 113 (Tex. App.-Austin 2003) (agency deference; PIA interpretation principles)
Jackson v. State Office of Admin. Hearings, 351 S.W.3d 290 (Tex. 2011) (liberal construction of PIA; public information policy)
City of Garland v. Dallas Morning News, 22 S.W.3d 351 (Tex. 2000) (contextual interpretation; public information disclosure emphasis)
Entergy Gulf States, Inc. v. Summers, 282 S.W.3d 433 (Tex. 2009) (statutory construction rules and deference considerations)