Robinson v. Parker, 353 S.W.3d 753

Houston citizens Robinson, Hotze, and Daily helped draft and signed a petition to place Prop. 2 on the ballot and supported Prop. 1 as well.
Prop. 2 and Prop. 1 passed in Houston’s November 2, 2004 election; City determined Prop. 2 ineffective due to Prop. 1’s higher votes and a supposed 'poison pill' provision.
The mayor did not certify Prop. 2 results to the secretary of state, and the City Council did not enter an adoption order.
Petitioners pursued mandamus relief in the appellate court, which held the City failed ministerial duties; Petitioners then filed a declaratory judgment suit to enforce Prop. 2.
City later treated Prop. 1 and Prop. 2 as part of the Houston City Charter, with Prop. 1 prevailing in votes, affecting enforcement.
Trial court granted summary judgment for Petitioners; the court of appeals held Petitioners lacked standing and remanded to establish standing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Ripeness and standing to challenge Prop. 2	Robinson argues Petitioners have standing to seek declaratory relief and enforcement.	City contends claims are not ripe; no concrete injury shown yet.	Claims not ripe; dismissed for lack of jurisdiction; no ruling on standing merits.
Merits of Prop. 2 validity	Robinson would have Prop. 2 enforced if ripe.	City asserts Prop. 2 is unenforceable due to conflicts with Prop. 1 and charter provisions.	Not addressed due to ripeness; court refrains from ruling on merits.

Brown v. Todd, 53 S.W.3d 297 (Tex. 2001) (standing must be established; has been cited for lack of standing principles)
Gibson, 22 S.W.3d 849 (Tex. 2000) (ripeness tied to concrete injury and developed facts)
Patterson v. Planned Parenthood of Hous. & Se. Tex., 971 S.W.2d 439 (Tex. 1998) (need for concrete injury to avoid advisory opinions)
Perry v. Del Rio, 66 S.W.3d 239 (Tex. 2001) (uncertain or contingent future events render suits unripe)