Cecile Erwin Young, in Her Official Capacity as the Executive Commissioner of the Texas Health and Human Services Commission v. Cook Children's Health Plan, Texas Children's Health Plan, Superior HealthPlan, Inc., and Wellpoint Insurance Company

ACCEPTED
15-24-00114-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
12/22/2025 3:46 PM
No. 15-24-00114-CV CHRISTOPHER A. PRINE
CLERK
FILED IN
IN THE COURT OF APPEALS FOR THE FIFTEENTH DISTRICT OF TEXAS
15th COURT OF APPEALS
AUSTIN, TEXAS
12/22/2025 3:46:41 PM
CHRISTOPHER A. PRINE
CECILE ERWIN YOUNG, IN HER OFFICIAL CAPACITY AS EXECUTIVE
Clerk
COMMISSIONER OF THE TEXAS HEALTH AND HUMAN SERVICES COMMISSION,
Appellant,

v.

COOK CHILDREN’S HEALTH PLAN; TEXAS CHILDREN’S HEALTH PLAN;
SUPERIOR HEALTHPLAN, INC.; AND WELLPOINT INSURANCE COMPANY,
Appellees.

On Appeal from the 455th Judicial District Court, Travis County, Texas
Cause No. D-1-GN-24-003839

APPELLEES’ JOINT REPLY IN SUPPORT OF
MOTION FOR REHEARING OF RULE 29.3 MOTIONS
INTRODUCTION

The Commissioner has demonstrated by her arguments and actions that she is

intent on avoiding any meaningful judicial review of the trial court’s finding that she

likely violated more than a dozen Texas laws. Instead, she seeks to finalize the

procurement and execute contracts with the intended awardees at the earliest

opportunity, which could moot the appeal. The Court’s denial of Appellees’ Rule

29.3 motions, based solely on the standstill agreement, inadvertently makes it

possible that the Commissioner could execute contracts without any court fully

considering whether Appellees face a risk of imminent, irreparable harm and before

this Court could act to preserve its jurisdiction to decide whether the Commissioner’s

administration of the procurement is unlawful.

Appellees’ concern that the Commissioner is laying the groundwork for a

mootness argument is not mere conjecture. Her predecessor made a similar

maneuver in Wilson v. Community Health Choice Texas, Inc., 607 S.W.3d 843, 848

(Tex. App.—Austin 2020, pet. denied), by executing contracts during litigation over

the legality of the procurement and then arguing that his action made the litigation

moot. Thus, this Court should reconsider Appellees’ Rule 29.3 motions and reinstate

the trial court’s injunction to prevent irreparable harm and preserve the Court’s

jurisdiction until the appeal is decided. Alternatively, the Court should extend its

administrative stay to permit Appellees to renew their motions should the Supreme

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Court deny relief. Simply put, this indisputably important matter—in which the trial

court has already found the Commissioners’ conduct ultra vires and which affects

access to healthcare for millions of Texans—deserves substantive judicial review.

ARGUMENT

I. The Commissioner’s response confirms her intent to move forward with
executing contracts, causing imminent, irreparable harm to Appellees
and threatening this Court’s jurisdiction.

The Commissioner’s response to the motion for rehearing and her other

communications to Appellees and the Court confirm that Appellees face imminent,

irreparable harm and highlight the need for relief from this Court. In her response,

the Commissioner confirms her position that if the Supreme Court denies the

mandamus petitions (even without any consideration of the merits), then the parties’

agreement would not prevent her from executing the contracts while this Court

considers renewed motions for a temporary order. Resp. at 2 n.1.

The Commissioner’s position is consistent with her repeatedly signaled intent

to move forward with the very conduct that the trial court found is likely ultra vires.

At the temporary-injunction hearing, the Commissioner testified that she would be

able to move forward with the procurement (including executing the contracts)

immediately after being released from any judicial prohibition. 6RR:147.1 More

1
The Commissioner has argued that she first has to decide the pending
administrative appeals. Appellant’s Br. at 11. But as discussed in Appellees’ briefs,

2
recently, in objecting to Appellees’ request for an extension of time to file their

merits briefs, she again indicated her intent to execute the contracts, if possible, even

before this Court can reach the merits of her appeal. She has refused to agree to even

a short standstill to allow Appellees time to seek additional temporary relief, if

necessary. See Ex. 1. And, most recently, when asking for an extension of time to

file her reply brief on the merits and to continue the date for oral argument (after

stridently opposing an extension request by Appellees), the Commissioner again

would not commit to waiting for this Court to decide the appeal on the merits before

she executes contracts. See Ex. 2.

In short, there can be no doubt that without this Court’s intervention, the

Commissioner will execute the contracts as soon as she believes (wrongly or not)

that the existing protections under the standstill agreement have expired, before

Appellees or the Court have time to prevent irreparable harm and preserve the

Court’s jurisdiction. And if given the opportunity, the Commissioner will almost

her arguments in this Court make clear she intends to deny those appeals. For
example, she justified her opposition to Appellees’ request for additional time to file
their response briefs on the ground that Appellees should not receive any further
payments “for contracts they did not win” and “to which they ha[ve] no
entitlement.” Resp. to Second Mot. for Extension of Time at 2 (emphasis added);
see also id. at 3 (describing Appellees’ case as “meritless”).

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certainly argue—as her predecessor did in Wilson—that Appellees’ claims have

been rendered moot by her execution of contracts with the intended awardees.2

II. The Court should not use the parties’ temporary standstill agreement to
sidestep a full analysis of the irreparable harm Appellees face.

The Commissioner does not dispute that the purpose of the parties’ standstill

agreement was to enable this Court to fully consider Appellees’ arguments for a

temporary order without the need for emergency action by the Court. And she “did

not raise the ground that this Court relied upon” to deny Appellees’ Rule 29.3

motions—that the standstill agreement precludes any irreparable harm to Appellees.

See Resp. at 1–2. Yet she still asks this Court to adopt an approach at odds not only

with the parties’ standstill agreement but also with the Court’s obligation to consider

the irreparable harm that the trial court found Appellees face if the Commissioner is

permitted to continue her ultra vires conduct.

By relying on the standstill agreement to limit its harm analysis, the Court

misapplied the standard for determining irreparable harm. See In re State, 711

2
The Commissioner also continues to argue that Appellees’ claims of harm are not
yet ripe. Resp. at 3. But the Commissioner’s avowed intent to move forward as soon
as she believes she is allowed belies this assertion. The Court should reject the
Commissioner’s incorrect and impossible ripeness standard, under which no claim
is ripe until it has become moot because the harm has already occurred. Ripeness
requires only that the alleged harm is likely to occur. See Patel v. Tex. Dep’t of
Licensing & Regulation, 469 S.W.3d 69, 78 (Tex. 2015) (noting that ripeness
requires only that harm “has occurred or is likely to occur”).

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S.W.3d 641, 645 (Tex. 2024) (“The applicant for a stay pending appeal should be

expected to show that he will suffer irreparable harm if relief is not granted.”). The

Court concluded that Appellees failed to show “irreparable harm if this Court does

not grant” the relief sought. Order at 3 (emphasis added). But the standard does not

ask whether harm may occur “if this court” does not grant the requested injunction.

Stated in the passive voice—“if relief is not granted”— the standard asks what harm

might result if no court grants the injunction. In other words, the “irreparable harm”

requirement asks whether, absent a court injunction—i.e., absent intervention by the

judiciary—there is a threat of imminent, irreparable harm to the party. If so, the court

should issue the requested injunction; the party need not demonstrate that, absent an

injunction from the court from whom relief is sought, appellate review to obtain that

relief would also fail. Cf. Huynh v. Blanchard, 694 S.W.3d 648, 675, 679–80 (Tex.

2024) (noting that “the nuisance will intermittently continue in the same unremitting

way absent an injunction”).

The mere fact that a party might obtain relief from a higher court does not

mean that the party faces no imminent, irreparable harm. Taking that position to the

logical conclusion, a trial court would have to deny all requests for injunctive relief

because the plaintiff might be able to obtain an appellate injunction or Rule 29.3

relief—an unintended result.

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The parties’ agreement does not preclude relief from this Court. It provides

only a temporary standstill; it does not protect Appellees (or the Court’s jurisdiction)

through resolution of the appeal. If the Supreme Court denies mandamus review, the

Commissioner has already said that she believes there will be nothing to stop her

from executing the contracts before this Court rules on the merits of her pending

appeal. See Resp. at 2 n.1. Thus, the Court should have considered not just the

temporary protection of the standstill agreement but also the imminent and

irreparable harm Appellees face should the Commissioner continue with the

procurement and execute contracts before final resolution of the appeal. And because

the Court did not do so, it did not provide the necessary review to safeguard

Appellees’ constitutional rights. See In re Geomet Recycling LLC, 578 S.W.3d 82,

89 (Tex. 2019) (orig. proceeding); In re Tex. Educ. Agency, 619 S.W.3d 679, 689–

90 (Tex. 2021) (orig. proceeding). 3

Additionally, the Court did not consider Wellpoint’s alternative request for a

writ of injunction to protect the Court’s jurisdiction, which does not require a

3
This approach also honors the text of Rule 6.6, under which “an agreement is
subject to any appellate court order necessary to ensure that the case is properly
presented.” TEX. R. APP. P. 6.6. The intent of the parties’ Rule 6.6 agreement was to
enable—not curtail—the Court’s power to fully consider whether Rule 29.3 relief is
appropriate.

6
showing of irreparable harm. 4 Thus, any lack of irreparable harm was not a proper

ground for denying the petition for writ of injunction.

The Commissioner insists there is no constitutional problem here because

Appellees filed mandamus petitions in the Supreme Court. Resp. at 3. But she

ignores the difference between a motion for a temporary order in the court of appeals

and a mandamus petition in the Supreme Court. While this Court is required to

consider all issues presented in the motion that are necessary to decide it, the

Supreme Court can deny review without considering any merits arguments. See In

re Novartis Pharms. Corp., No. 24-0239, 2025 WL 2989490, at *4 (Tex. Oct. 24,

2025) (op. on denial of mandamus) (observing that Supreme “Court’s failure to grant

a petition for writ of mandamus is not an adjudication of, nor even a comment on,

the merits of a case in any respect, including whether mandamus relief was

available”). The Commissioner overlooks this key point: the procedural right to ask

the Supreme Court to review this Court’s denial of Rule 29.3 relief is not the

4
Appellees have found no Texas case in which a court of appeals invoking
Government Code section 22.221(a) or its predecessor has engaged in “irreparable
harm” analysis in assessing whether to issue the writ of injunction to protect the
court of appeals’ jurisdiction. Rather, for purposes of such relief, the parties’ rights
do not matter. See, e.g., Pace v. McEwen, 604 S.W.2d 231, 233 (Tex. Civ. App.—
San Antonio 1980, orig. proceeding) (noting that appellate courts could issue
injunctions solely to protect their jurisdiction “and not for the purpose of protecting
a litigant,” and observing that the court’s “exercise of that power in no degree
depends upon the rights of a litigant or the remedies available to him.”).

7
equivalent of the right to have this Court’s meaningful assessment, in the first

instance, of that request for relief. Thus, the fact that the standstill agreement remains

in effect while Appellees seek mandamus relief in the Supreme Court should not

have affected the irreparable harm analysis.

The Commissioner misconstrues Appellees’ argument, insisting that

Appellees received full consideration of the merits of their Rule 29.3 motions

because the Court’s denial based on the standstill agreement was a “ruling on the

merits.” Resp. at 2–3. But she does not (and cannot) dispute that this Court’s order

did not address the imminent and irreparable harm Appellees face should the

Commissioner execute contracts before final resolution of the appeal. Id.

Finally, using a standstill agreement as the ground to deny a Rule 29.3 motion

will also have the perverse effect of increasing inefficiency in these types of appeals.

The undisputed purpose of the agreement was to preserve judicial resources by

obviating the need for emergency motions and immediate action by this Court in

considering Appellees’ Rule 29.3 motions, avoiding the risk of the Commissioner

potentially mooting those motions before a decision was made. After the Court’s

order, these agreements may be deemed too risky by future litigants, who will feel

compelled to burden the appellate courts with additional emergency motions.

By invoking the parties’ temporary standstill agreement to sidestep full

consideration of the imminent harm Appellees face, the Court has undermined the

8
protections that Rule 29.3 (and appellate injunctions) should provide to parties trying

to stop governmental officials from acting ultra vires. The Court should grant

rehearing to fully consider the harm Appellees face (and the threat to this Court’s

jurisdiction) in deciding whether to prevent the Commissioner from proceeding with

the procurement (including executing contracts) pending resolution of her appeal.

III. The Commissioner’s merits arguments against a temporary order are
unavailing.

The Commissioner’s response also recycles her arguments on the merits of

Appellees’ motions, continuing to mischaracterize the claims and relief sought.

Resp. at 4–7. Appellees have addressed these arguments in their prior briefing and

will not belabor those points here. But they note that the Commissioner’s insistence

that her interests are the same as the public interest fundamentally misunderstands

the nature of an ultra vires claim. The Commissioner has no protectable interest in

continuing to violate the law. See In re State, 711 S.W.3d 641, 648 (Tex. 2024) (orig.

proceeding) (“The County is not harmed by being required to follow the Texas

Constitution.”). And her argument that the State suffers irreparable injury if it is

“enjoined by a court from effectuating statutes enacted by representatives of its

people,” Resp. at 6, gets it all wrong. As the trial court found, the Commissioner is

(and would be) defying—not effectuating—the Legislature’s statutes. In analyzing

whether a temporary order is proper, the Court should take into account the trial

court’s detailed factual findings that Appellees will likely succeed on their claim that

9
the Commissioner is acting ultra vires. These findings demonstrate that the

Commissioner is acting in violation of the laws governing procurements, and the

public interest is undoubtedly served by enjoining any further unlawful conduct.

The Commissioner’s recent insistence on immediately finalizing the

procurement and her arguments of alleged harm from delay ignore her earlier

agreements to postpone execution of contracts until after the temporary-injunction

hearing (CR:2629), during the Legislative session (Ex. B to Superior’s 29.3 Motion),

and until after Appellees sought temporary orders on appeal (id.). Yet the

Commissioner continues to make hyperbolic, evidence-free claims about the

injunction “jeopardiz[ing] the healthcare of over four million Texans,” Resp. at 7,

even though no harm has befallen the Commissioner or the people of Texas in the

intervening fourteen months while the procurement has been stayed. The

Commissioner has never, in all her various briefs, identified any evidence of any

harm caused by the temporary injunction, and she has not explained why a short

additional delay until the appeal is resolved is any different from the lengthy delay

she already agreed to, especially given this Court’s stated intent to expeditiously

resolve the appeal. In contrast, the Commissioner’s rush to execute contracts that the

trial court found are likely illegal based on the Commissioner’s ultra vires conduct—

before this Court even has an opportunity to rule on the pending appeal— will

irreparably harm Appellees, the State, and STAR & CHIP members.

10
IV. In any event, the Court should extend the administrative stay to protect
Appellees and its own jurisdiction until full consideration of Appellees’
motions occurs.

If the Court does not grant rehearing, it should nevertheless extend its

administrative stay until after the Supreme Court disposes of Appellees’ mandamus

petitions and Appellees have the opportunity to seek additional relief in this Court,

if needed. If the Supreme Court denies mandamus relief, that would eliminate this

Court’s stated basis for denying Appellees’ motions by removing resort to the

Supreme Court as protection against imminent harm. In that instance, Appellees will

return to this Court to re-urge their motions in light of the changed circumstances.

But as discussed above, the Commissioner believes that a Supreme Court denial

would terminate the standstill agreement’s protection and allow her to immediately

proceed with the contract awards. This action could be accomplished very quickly,

even before Appellees could secure temporary emergency relief from this Court. To

protect Appellees and its own jurisdiction, the Court should extend its administrative

stay to ensure that the Commissioner cannot act until after this Court rules on any

renewed motions for a temporary order following the Supreme Court’s decision.

CONCLUSION AND PRAYER

The Court should grant Appellees’ motions for rehearing and fully consider

their arguments about the imminent, irreparable harm they face in the absence of

relief from this Court reinstating the trial court’s temporary injunction pending

11
resolution of the Commissioner’s appeal. Alternatively, the Court should continue

its administrative stay until after the Supreme Court resolves Appellees’ mandamus

petitions and this Court has had the opportunity to consider Appellees’ renewed

requests for relief in this Court. Appellees also request any other relief to which they

are entitled.

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Respectfully submitted,

/s/ Susan Feigin Harris /s/ Amy Warr
Susan Feigin Harris Amy Warr
State Bar No. 06876980 State Bar No. 00795708
susan.harris@nortonrosefulbright.com awarr@adjtlaw.com
Warren S. Huang Anna M. Baker
State Bar No. 00796788 State Bar No. 00791362
warren.huang@nortonrosefulbright.com abaker@adjtlaw.com
NORTON ROSE FULBRIGHT US, LLP ALEXANDER DUBOSE & JEFFERSON
1550 Lamar, Suite 2000 LLP
Houston, Texas 77010 100 Congress Avenue, Suite 1450
Telephone: (713) 651-5151 Austin, Texas 78701-2709
Telephone: (512) 482-9300
Paul Trahan
State Bar No. 24003075 Karen C. Burgess
paul.trahan@nortonrosefulbright.com State Bar No. 00796276
NORTON ROSE FULBRIGHT US, LLP kburgess@burgesslawpc.com
98 San Jacinto Boulevard, Suite 1100 Katie Dolan-Galaviz
Austin, Texas 78701 State Bar No. 24069620
Telephone: (512) 474-5201 kgalaviz@burgesslawpc.com
BURGESS LAW PC
Thomas A. Coulter 404 West 13th Street
State Bar No. 04885500 Austin, Texas 78701-1825
tom.coulter@nortonrosefulbright.com Telephone: (512) 482-8808
NORTON ROSE FULBRIGHT US, LLP
799 9th Street, NW, Suite 1000 Matthew P. Gordon
Washington, D.C. 20001 Admission Pro Hac Vice
Telephone: (202) 662-0200 mgordon@perkinscoie.com
PERKINS COIE LLP
COUNSEL FOR APPELLEE TEXAS 1301 Second Avenue, Suite 4200
CHILDREN’S HEALTH PLAN Seattle, Washington 98101
Telephone: (206) 359.8000

COUNSEL FOR APPELLEE COOK
CHILDREN’S HEALTH PLAN

13
HOLLAND & KNIGHT LLP /s/ Stacy R. Obenhaus
Stacy R. Obenhaus
By: /s/ Richard B. Phillips, Jr. Texas Bar No. 15161570
Richard B. Phillips, Jr. sobenhaus@foley.com
Texas Bar No. 24032833 Michelle Y. Ku
rich.phillips@hklaw.com Texas Bar No. 24071452
mku@foley.com
One Arts Plaza FOLEY & LARDNER LLP
1722 Routh Street, Suite 15500 2021 McKinney, Suite 1600
Dallas, Texas 75201 Dallas, Texas 75201
(214) 964-9500 (telephone) Telephone: (214) 999-3000
(214) 964-9501 (facsimile)
Robert F. Johnson III
Karen D. Walker Texas Bar No. 10786400
Admitted Pro Hac Vice rjohnson@foley.com
karen.walker@hklaw.com FOLEY & LARDNER LLP
Tiffany Roddenberry 600 Congress, Suite 3000
Admitted Pro Hac Vice Austin, Texas 78701
tiffany.roddenberry@hklaw.com Telephone: (512) 542-7000

315 S. Calhoun Street, Suite 600 COUNSEL FOR APPELLEE WELLPOINT
Tallahassee, Florida 32301 INSURANCE COMPANY
(850) 425-5612 (telephone)
(850) 224-8832 (facsimile)

COUNSEL FOR APPELLEE SUPERIOR
HEALTHPLAN, INC.

14
CERTIFICATE OF COMPLIANCE

Pursuant to Texas Rule of Appellate Procedure 9.4(i)(3), I certify that this

reply contains 2,807 words, excluding the contents listed in Rule 9.4(i)(1).

/s/ Richard B. Phillips, Jr.
Richard B. Phillips, Jr.

15
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Richard Phillips on behalf of Richard Phillips Jr.
Bar No. 24032833
Rich.Phillips@hklaw.com
Envelope ID: 109380897
Filing Code Description: Other Document
Filing Description: Appellees' Joint Reply in Support of Motion for
Rehearing of Rule 29.3 Motions
Status as of 12/22/2025 3:52 PM CST

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Bar No. 24032833
Rich.Phillips@hklaw.com
Envelope ID: 109380897
Filing Code Description: Other Document
Filing Description: Appellees' Joint Reply in Support of Motion for
Rehearing of Rule 29.3 Motions
Status as of 12/22/2025 3:52 PM CST

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