Greg Abbott, Attorney General of the State of Texas v. City of Dallas, 453 S.W.3d 580

City of Dallas received a Public Information Act (PIA) request about landfill operations; the City sought to withhold certain documents as attorney-client communications.
The City asked the Texas Attorney General (AG) for a ruling but missed the PIA’s 10-business-day deadline to request an AG opinion under Tex. Gov’t Code §552.301(b).
The AG’s letter ruling acknowledged the documents were privileged but held the privilege must be asserted under §552.107(1) (a discretionary exception) and that, because the City missed the deadline, the City needed an independent "compelling reason" to withhold the records under §552.302.
The City sued the AG for declaratory relief under §552.324, asserting the documents were exempt under §552.101 and §552.107(1) because they were protected by the attorney-client privilege.
The trial court granted summary judgment for the City, concluding attorney-client privilege is an inherently compelling reason to withhold the information; the AG appealed.
The court of appeals affirmed, holding attorney-client privileged information falls within §552.101 and that the City demonstrated a compelling reason to withhold the records.

Issue	Plaintiff's Argument (City)	Defendant's Argument (AG)	Held
Whether attorney-client privileged communications can be withheld under §552.101 (information "considered confidential by law").	Attorney-client privilege is "law" outside the PIA (Rules of Evidence / Disciplinary Rules) and therefore falls within §552.101.	Attorney-client privilege must be asserted under §552.107(1), not §552.101; §552.107(1) is discretionary and can be waived.	Held: Privileged attorney-client communications are encompassed by §552.101; Rules of Evidence and Disciplinary Rules constitute "law" outside the PIA.
Effect of missing the §552.301(b) deadline — does the City still have a "compelling reason" to withhold privileged material under §552.302?	The City: attorney-client privilege itself (and the policy protecting it) is a compelling reason to overcome the presumption of disclosure after missing the deadline.	The AG: because §552.107(1) is discretionary and waivable, the City must show an independent compelling reason beyond the privilege to withhold information.	Held: Because the City established the documents are protected by the attorney-client privilege and the privilege falls under §552.101, that protection constitutes a compelling reason; information need not be disclosed despite the missed deadline.

City of Garland v. Dallas Morning News, 22 S.W.3d 351 (Tex. 2000) (PIA construction; §552.101 includes information considered confidential by law)
In re City of Georgetown, 53 S.W.3d 328 (Tex. 2001) (Rules of Evidence and Civil Procedure are "other law" outside the PIA; court rule-based privileges qualify)
Upjohn Co. v. United States, 449 U.S. 383 (U.S. 1981) (describing attorney-client privilege as an established common-law privilege)
In re Smith, 333 S.W.3d 582 (Tex. 2011) (attorney general opinions persuasive but not binding; procedural context on AG opinions)
City of Dallas v. Abbott, 304 S.W.3d 380 (Tex. 2010) (prior appellate treatment of missed §552.301(b) deadline; discussed but distinguished)