The opinion
ACCEPTED
15-25-00008-CV
Case No. 15-25-00008-CV Appellant Reply Brief FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
6/13/2025 6:44 AM
CASE NO. 15-25-00008-CV CHRISTOPHER A. PRINE
CLERK
FILED IN
15th COURT OF APPEALS
In the Court of Appeals AUSTIN, TEXAS
6/13/2025 6:44:58 AM
for the Fifteenth Judicial District of Texas CHRISTOPHER A. PRINE
Clerk
Linda D. Tanner
Appellant,
vs.
Texas Health and Human Services Commission, Juan Rodriguez,
Wendy Proctor, and Julia Murray
Appellees,
On Appeal from the 459th Judicial District Court
Travis County, Texas
Cause No. D-1-GN-24-002987
Honorable Judge Laurie Eiserloh
Appellant Reply Brief
Linda D. Tanner
Pro Se
Lulu143134143@gmail.com
2121 Handley Drive
Apt 51
Fort Worth, TX 76112
817-204-8004
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Certificate of Interested Persons
Appellant, Linda D. Tanner, certifies that the following listed persons and entities as
described in the fourth sentence of Rule 28.2.1 have an interest in the outcome of this case.
Appellant: Counsel for Appellant:
Linda D. Tanner Pro Se Litigant
2121 Handley Drive
Apt 51
Fort Worth, TX 76112
Tel: 817-204-8004
lulu143134143@gmail.com
Appellees: Counsel for Appellees:
Texas Health and Human Services Commission Giselle Ortiz Astacio
Juan Rodriguez Texas State Bar No. 24103222
Wendy Proctor Lauren McGee
Julia Murray Texas State Bar No. 24128835
Assistant Attorney General
Office of the Attorney General of Texas
Administrative Law Division
P.O. Box 12548, Capitol Station
Austin, TX 78711-2548
Telephone: (512) 475-4200
Griselle.OrtizAstacio@oag.texas.gov
Lauren.McGee@oag.texas.gov
Respondent:
Honorable Judge Laurie Eiserloh
459th Judicial District Court
1700 Guadalupe,
11th Floor
Austin, TX 78701
Tele: 512-854-9384
Fax: 512-854-9338
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Table of Contents
1. Table of Statutes& Authorities……………………………………………4
2. Argument………………………………………………………………….6
Introduction……………………………………………………………6
I. Sovereign Immunity…………………………………………………7
II. The Fourteenth Amendment of the United States Constitution…….9
III. The Supremacy Clause and The Social Security Act Title IV-A….13
IV. Compliance with State and Federal Laws………………………….14
V. Untimeliness of Filing Plaintiff’s Petition…………………………..17
3. Conclusion………………………………………………………………….21
4. Prayer………………………………………………………………………22
5. Certificate of Compliance………………………………………………….23
6. Certificate of Service……………………………………..………………..24
7. Appendix…………………………………………………...………………25
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Table of Authorities & Statutes
Statutes
1. United States Constitution, Article VI, Clause 2, The Supremacy Clause and
the Preemption Doctrine…………………………………….……………..13
2. The Fourteenth Amendment, U.S. Constitution……………………...….9, 14
3. The Voidness Doctrine………………………………………………………7
4. United States Code Title 42 § 1983……………………………………..8, 20
5. Social Security Act Title IV-A…………………………9, 12, 13, 14, 15, 16
6. Code of Federal Regulations (CFR), Title 45, Subtitle B, Chapter II, Parts
260-265, Parts 205-206……………………………..…9, 12, 13, 14, 15, 16
7. Texas Administrative Code (TAC), Title 1, Part 15, Subchapter B, Division
7, Chapter 372………………………………………………..…..11, 14, 15
8. SI 00830.403 Temporary Assistance for Needy Families (TANF)………14
9. Texas Human Resource Code, Title 2, Subtitle C, Chapter 31, Subtitle A..14
10. Tex. Gov’t Code Chapter 525……………………………………………..14
11. Texas Penal Code § 37.10…………………………………………………20
12. Texas Penal Code § 39.02………………………………………………….20
13. Texas Works Handbook - C-110-TANF…………………………………..11
14. Texas Works Handbook – C-111-Income Limits…………………………11
15. Texas Works Handbook- A-1341.1 - Grant Amount……………………..11
Authorities
1. Will v. Michigan Dept. of State Police (1989)…………………………….…9
2. Hafer v. Melo
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502 U.S. 21 (1991)………………………………………………………….….9
3. Blum v. Bacon
(457 U.S. 132, 1982) ………………………………………………………………………. 13
4. Carrie Hendrick v. New Hampshire Department of Health and Human Services
(2016) No. 2015-
0442……………………………………………………………….………….13
5. Arizona v. United States (2012)
567 us 387……………………………………………………………………14
6. United States v. Curtiss-Wright Export Corp.,
299 U. S. 304, 318 (1936) ………………………………………………….14
7. National Association of Chain Drug Stores, Inc. v. Cecile Young (2024)
No. 07-23-00175-CV, Tex. Ct. App. 7th Dist……………………….……14
8. McMillen v. Tex. Health & Human Servs. Comm’n (2016)
No. 15-0147, Supreme Court of Texas……………………………………16
9. LVNV Funding, LLC v. Trice,
2015 IL 116129…………………………………………………………..….7
10. 30A Am Jur Judgments '' 44, 45……………………………………..…..….7
11. Earle v. McVeigh,
91 US 503, 23 L Ed 398………………………………………………..….10
12. Hanson v Denckla,
357 US 235, 2 L Ed 2d 1283, 78 S Ct 1228………………………………10
13. Rose v. Himely
(1808) 4 Cranch 241, 2 L ed 608……………………………………….…..7
14. Pennoyer v. Neff
(1877) 95 US 714, 24 L ed 565……………………………………………7
15. Thompson v. Whitman
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(1873) 18 Wall 457, 21 l ED 897……………………………………………7
16. Windsor v. McVeigh
(1876) 93 US 274, 23 L ed 914……………………………………………..7
17. McDonald v. Mabee
(1917) 243 US 90, 37 Sct 343, 61 L ed 608……….......................................7
18. U.S. v. Holtzman
762 F.2d 720 (9th Cir. 1985) ……………………………………………..10
19. Sabariego v Maverick
124 US 261, 31 L Ed 430, 8 S Ct 461……………………………………..10
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Argument
Introduction
Plaintiff, Linda D. Tanner, Pro Se, brings forth this argument in response to
the Appellee Brief filed May 29, 2025. The issue that is ultimately in question in
this appeal is whether the trial court properly dismissed the plaintiff’s suit for
judicial review due to a lack of subject matter jurisdiction and legal standing. The
appellees’ argument is that the lack of subject matter jurisdiction is due to the
untimeliness of the filing of the original petition for review by the plaintiff and that
she did not meet statutory requirements. They also state the claims for
constitutional violations and federal and state non-compliance are barred due to
sovereign immunity.
Pursuant to the Voidness Doctrine, any dismissal that is due to lack of
subject matter jurisdiction is considered null and void because a court without
jurisdiction has no legal authority to rule on the case. Judgments issued without
jurisdiction are legally null and unenforceable. “Void or voidable was ultimately a
question of jurisdiction,” LVNV Funding, LLC v. Trice, 2015 IL 116129 “A void
judgment does not create any binding obligation.” Kalb v. Feuerstein (1940) 308
US 433, 60 S Ct 343, 84 L ed 370; “An order that exceeds the jurisdiction of the
court, is void, or voidable, and can be attacked in any proceeding in any court
where the validity of the judgment comes into issue.” Rose v. Himely (1808) 4
Cranch 241, 2 L ed 608; “All proceedings founded on the void judgment are
themselves regarded as invalid.” 30A Am Jur Judgments 44, 45
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I. Sovereign Immunity
Sovereign immunity is a legal doctrine used to protect federal and state
entities from being sued without the permission of itself. However, sovereign
immunity is not waived for government officials representing a state entity being
sued in their personal or individual capacity. The Appellant, Linda D. Tanner, has
stated numerous times in the petition and pleadings in the clerk’s record from the
trial court, 459th Judicial District Court, Travis County, Texas and the Appellate
Brief in the above numbered appeal that the Defendant’s Juan Rodriguez, Wendy
Proctor, and Julia Murray are being sued in their personal or individual capacities.
In this case, sovereign immunity is waived with respect to U.S. Code Title 42 §
1983 – Civil Action for Deprivation of Rights, which gives the state’s consent to
suit by reference to a statute and legislative permission. U.S. Code Title 42 § 1983
is a federal cause of action for individuals whose constitutional rights have been
violated by persons acting under color of state law. U.S. Code Title 42 § 1983
expresses legislative permission and waives the sovereign immunity for state
officials that are being sued in their individual or personal capacities for acts of
neglect and bad faith displayed under their authority while representing a
government entity such as the Texas Health and Human Services Commission.
This directly relates to the plaintiff’s constitutional rights being violated as
previously stated in the trial court’s record and the appellate brief for this
appeal. “the Court of Appeals found that respondents sought damages from Hafer
in her personal capacity and held that, because she acted under color of state law,
respondents could maintain a § 1983 individual-capacity suit against her.”
“Personal-capacity suits, on the other hand, seek to impose individual liability
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upon a government officer for actions taken under color of state law. Thus, "[o]n
the merits, to establish personal liability in a § 1983 action, it is enough to show
that the official, acting under color of state law, caused the deprivation of a federal
right." Hafer v. Melo, 502 U.S. 21 (1991) “Neither States nor state officials acting
in their official capacities are "persons" within meaning of § 1983.” Will v.
Michigan Dept. of State Police (1989) However, individuals, municipalities, and
state officials sued in their personal capacity are considered “persons” under U.S.
Code Title 42 § 1983 and can be held liable for constitutional violations.
The defendants in this cause have originally tried to claim qualified
immunity in their affirmative defenses. Qualified immunity, by definition, is used
to protect government officials from a lawsuit unless their actions violated clearly
established statutory or constitutional rights. Claiming qualified immunity would
be invalid and unlawful in this case. The defendants have neglected the plaintiff’s
constitutional rights and violated clearly established constitutional and statutory
laws that are in place for the Texas Temporary Assistance for Needy Families
(TANF) Cash Help Program. They directly violated the plaintiff’s Fourteenth
Amendment of the U.S. Constitution procedural due process clause and the equal
protection clause. They are not applying the applicable federal and state laws and
guidelines in place for the TANF Cash Help Program which makes them
noncompliant with state and federal regulations. This makes them noncompliant
with the Code of Federal Regulations (CFR) Title 45, Chapter II, Parts 260-265,
and The Social Security Act Title IV-A.
II. The Fourteenth Amendment of the United States Constitution
The Fourteenth Amendment of the United States Constitution ensures the
government follows fair procedures before depriving a person of life, liberty, or
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property. This includes the civil rights of procedural due process and equal
protection. “A judgment may not be rendered in violation of constitutional
protections.” “The validity of a judgment may be affected by a failure to give the
constitutionally required due process notice and an opportunity to be heard.” Earle
v. McVeigh, 91 US 503, 23 L Ed 398 “A judgment of a court without hearing the
party or giving him an opportunity to be heard is not a judicial determination of
his rights.” Sabariego v Maverick, 124 US 261, 31 L Ed 430, 8 S Ct 461
Let us remember that the rules of procedure exist to ensure fairness and
efficiency. That is the very foundation of civil rights in the United States of
America. “The limitations inherent in the requirements of due process and equal
protection of the law extend to judicial as well as political branches of
government, so that a judgment may not be rendered in violation of those
constitutional limitations and guarantees.” Hanson v Denckla, 357 US 235, 2 L Ed
2d 1283, 78 S Ct 1228.
The plaintiff was denied procedural due process nine times in this case. The
first two times was during the fair and fraud hearings that took place on December
6, 2023, January 17, 2024, and the Administrative Review that took place on
February 15, 2024. As a hearings officers and an administrative judge, it is
Defendant’s Juan Rodriguez’s, Wendy Proctor’s, and Julia Murray’s role to apply
procedural due process by evaluating evidence, ensuring fairness, and applying
legal standards to the facts presented. It is their responsibility to review and
analyze the statement of facts brought forth by the plaintiff. They failed to do that
during all three proceedings. Had they reviewed the statement of facts provided by
the plaintiff they would have easily seen where the mistakes were. They would
have easily seen that the issue with the ineligibility of the plaintiff was due to the
fact that the Texas Health and Human Services Commission officials, in their
individual capacities, have failed to apply the Federal Poverty Levels to the two
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tests used to determine eligibility. These tests are called the Budgetary Needs Test
and the Recognizable Needs Test located in the Texas Administrative Code (TAC)
Title 1, Part 15, Subchapter B, Division 7, Chapter 372 § 372.408. They would
have also seen that the Budgetary Needs amounts are 100% of the Federal Poverty
Level and the Recognizable Needs are 25% of the Budgetary Needs amount which
is located in the Texas Works Handbook C-110-TANF – C-111- Income Limits.
Lastly, the max grant amounts are 17% of the Federal Poverty Level for the family
size of the applicant. From that number you subtract the eligible earned and/or
unearned income of the applicant and that is total amount of the monthly payments
the applicant would receive. This rule is located in the Texas Works Handbook- A-
1341.1 - Grant Amount.
The fact is they didn’t acknowledge any of the facts. They had no questions
for the plaintiff and frankly didn’t seem to want to hear anything she had to say
while stating her case during the hearings. They were uninterested in claims
regarding the applicable laws not being applied and completely ignored the
plaintiff’s statement of facts. Had they thoroughly analyzed the case made by the
plaintiff they would have seen the facts and mistakes and noticed that the
guidelines for the TANF Cash Help Program on the My Texas Benefits website,
the Texas HHSC website, and the MEPD and TW Bulletin all conflict with the
state and federal regulations for this program.
Also, one reasonable point that I would like to make is that the plaintiff was
making claims regarding common and clearly established laws that have been in
place for the Texas TANF Cash Help Program for a long time. This was not a
proposal of new laws by the plaintiff. It was and is not something she needs to
“talk to her congressman” about. These rules and statutes were and are applicable
by the officials in their individual roles of representing the state entity of the Texas
Health and Human Services Commission. That being said, the state officials
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completely ignored all claims and all facts clearly stated right in front of them. It
was a simple denial without review of the law. Because of the negligence and bad
faith displayed by the defendant’s actions in their individual roles as government
officials for the Texas Health and Human Services Commission, the plaintiff and
her family were evicted out of their residence and lacked food, shelter, clothing,
and other nondiscretionary items until taken in by an emergency shelter. She
wasn’t able to buy Christmas gifts for her children and also lost access to over half
of their belongings due to having no money. They were forced into homelessness
which could have completely been avoided had the state officials applied the
applicable laws when determining her eligibility for the program.
The third time the plaintiff was denied procedural due process of law was
during the judicial review in the trial court 459th Judicial District Court. The Texas
AOG defendants filed their answers and the plaintiff made a discovery request for
production of documents and interrogatories in light of the Public Information Act
(PIA). The defendants’ counsel refused to produce documents and answer
questions saying that it is not permitted pursuant to the Administrative Procedure
Act and that all discovery is exclusive to the administrative record. In turn, the
plaintiff responded clearly that it is permitted pursuant to the Administrative
Procedure Act because the judicial review requires further fact finding due to
agency misconduct and bad faith. The plaintiff filed a motion for discovery that
was never heard or acknowledge by the judge of the court or defendants’ counsel.
The Texas OAG again did not provide data collection and reporting pursuant to 45
CFR Part 265 when asked to provide as part of the PIA and The Social Security
Act IV-A Section 411.
There were several other pleadings filed by the plaintiff that were never
heard or acknowledged by the judge of the court and the defendants’ counsel. The
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plaintiff sent correspondence regarding the pleadings and never got any reply by
the defendant’s counsel; just completely ignored.
The other six times the plaintiff was denied procedural due process was
during the six times she has applied for the TANF Cash Help program since the
year 2021 and been denied every single time without full review of the income
limit amounts being used to decide eligibility.
III. The Supremacy Clause and The Social Security Act Title IV-A
The Supremacy Clause found in Article VI, Clause 2 of the U.S.
Constitution, states that “the Constitution, federal laws made pursuant to it,
and treaties made under its authority, constitute the "Supreme Law of the
Land”, and thus take priority over any conflicting state laws.” Under the
Supremacy Clause or Preemption Doctrine of the United States Constitution,
federal law takes precedence over conflicting state laws. This means that Texas
courts must comply with the Social Security Act Title IV-A and the Code of
Federal Regulations Title 45, Chapter II, provisions governing TANF cash
assistance programs being that they are, in fact, binding law. This means that
Texas courts cannot ignore claims of noncompliance with federal and/or state
regulations. “Because the New York provisions conflict with a valid federal
regulation promulgated by the Secretary of Health, Education, and Welfare
(Secretary) which proscribes inequitable treatment of individuals or groups under
an EA program, they are invalid under the Supremacy Clause.” Blum v. Bacon
(457 U.S. 132, 1982) “We agree with the Solicitor General that the Supremacy
Clause does not permit the State to redirect federal benefits as required by Rule
He-W 654.04(c)” Carrie Hendrick v. New Hampshire Department of Health and
Human Services (2016) No. 2015-0442 “This authority rests, in part, on the
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National Government’s constitutional power to “establish an uniform Rule of
Nat- uralization,” U. S. Const., Art. I, §8, cl. 4, and its inher- ent power as
sovereign to control and conduct relations with foreign nations” United
States v. Curtiss-Wright Export Corp., 299 U. S. 304, 318 (1936)
This also means that Texas courts must comply with the Fourteenth
Amendment of the United States Constitution provisions governing due process
and equal protection during the process of appeal, administrative review, judicial
review and so forth for TANF cash assistance programs being that they are, in fact,
binding law.
IV. Compliance with State and Federal Laws
Pursuant to Section 1116 of the Social Security Act Title IV-A and the Code
of Federal Regulations (CFR) Title 45 § 201, the state of Texas submits a state
plan that outlines the guidelines for the TANF Cash Help Program for approval.
The guidelines, rules, and statutes for the TANF Cash Help Program are located in
the State Plan, the Texas Administrative Code (TAC) Title 1, Part 15, Subchapter
B, Division 7, Chapter 372, the Code of Federal Regulations Title 45, Part 200-
205, Part 260-265, The Social Security Act Title IV-A, SI 00830.403 Temporary
Assistance for Needy Families (TANF), the Texas Human Resources Code
Chapter 31, and the Tex. Gov’t Code Chapter 525. These all have statutes outlining
the executive commissioner of the Texas HHSC’s responsibility to lawfully
distribute the federal block grants, federal funds, and any state funds to the active
programs offered by the Texas HHSC. It is also the executive commissioner’s
responsibility to update the program guidelines including eligibility income limits
when necessary and mandatory at least once a year. When is the last the time these
eligibility income limits were updated? “By failing to comply with her ministerial
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duties, Young acted ultra vires.” National Association of Chain Drug Stores, Inc.
v. Cecile Young (2024) No. 07-23-00175-CV, Tex. Ct. App. 7th Dist.
Pursuant to CFR Part 265.1-265.3, it is the responsibility of the executive
commissioner of the Texas HHSC to file quarterly and annual reports for the state.
Annual reports are due 45 days after the end of the fiscal year. Each report must
consist of TANF data reports, TANF financial reports, case record information, the
expenditure data, the definitions and other information on state’s TANF and MOE
(Maintenance of Efforts) programs, and work outcomes. This was the very
information the plaintiff was seeking in discovery from the Texas OAG and what
they unlawfully denied to give to her. Again, denying her of her civil rights of
procedural due process and equal protection.
The Texas TANF Cash Assistance program as outlined in the CFR, TAC,
and Social Security Act Title IV-A is in place to offer help with paying for
nondiscretionary items such as, clothing, food, housing payments, transportation,
furniture, phone, laundry, utilities, medical supplies, supplies for the home, and
other basic needs. This program is for reliable help for families when they need it
so that they can maintain their home while looking for work. The TANF Cash
Assistance program also offers ways to find and keep work as part of the
responsibility of staying eligible for the program. This is a serious program that
helps people and families in need. This program is designed to provide a financial
foundation to those in need and consistently provide cash support throughout the
time period needed (up to five years or 60 months). This allows citizens the chance
to “get on their feet” and stay there. It is a program designed to truly help. What is
currently being given does not give any support to families and is totally bogus.
The plaintiff has been denied this benefit 6 times since 2021 and she has
been very eligible for it each and every time. She has been unable to find
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employment for the last 4 years and this program could have really helped her and
her family.
Currently, the Budgetary and Recognizable Needs are set at unrealistic
amounts. In order for her to qualify, she would have to receive less than $188 a
month just to receive a little over $300 in max grants. That being said, they also
told her that she would have to surrender all of her child support payments
received from the absent parent and use it to pay back the funds she receives in the
TANF Cash help program. The fact is, applicants for TANF only have to get child
support payments arranged to be disbursed through the Texas OAG to keep record
of payments received. They do not have to give the money they receive as child
support for their child(ren) to the Texas HHSC and TANF Cash Help Program.
They do not have to pay back these funds. TANF Cash Help is a grant program not
a loan application. If the government officials of the Texas HHSC are forcing the
applicants to pay back the funds they get through the program, they are in extreme
violation of the Code of Federal Regulations and the Social Security Act Title IV-
A. They are in noncompliance of state and federal regulations and could potentially
be at risk for penalties outlined in the Code of Federal Regulations (CFR), Title 45,
Chapter II, Parts 260-265, specifically Part 262 and Part 265.8 – 265.9. “Yet the
OIG also has power to ensure “enforcement of state law relating to the provision
of” health and human services. Id. § 531.102(a). And state law mandates that the
Commission’s “executive commissioner shall ensure that Medicaid implements 42
U.S.C. Section 1396p(b)(1).” Id. § 531.077(a). Accordingly, the Commission has
authority to ensure compliance with section 1396p(b).” McMillen v. Tex. Health &
Human Servs. Comm’n (2016), No. 15-0147, Supreme Court of Texas
If they receive penalties for federal noncompliance, this means that federal
funding could stop completely. This puts all applicants and state citizens/residents
in an unlawful situation of being denied benefits due to lack of resources for the
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program. Again, depriving the public of their constitutional or civil rights. The
executive commissioner and the state government employees are responsible for
these penalties in their individual roles as officials representing the Texas HHSC
TANF programs, and could be held liable for their actions.
Considering all of the basic needs that the TANF Cash help program is
supposed to provide for, it is literally impossible to do that with the max grant
amounts that are in place. No one could reasonably live on the amounts being
given. Furthermore, taking a look at TANF One-Time payments, the income
eligibility guidelines are much higher than the yearly program income limits. What
is the reason for that? It is clear that the Texas Health and Human Services
Commission current guidelines conflict with state laws regarding the program.
They are in noncompliance of state and federal regulations in place that determine
the provisions on which the TANF Cash Help program benefits are provided.
Being that the plaintiff has been denied every single time she has either
applied for TANF Cash Help or appealed the agency decision, the Texas HHSC
has been in noncompliance of the rules and eligible income limits for a long time.
To the best of her knowledge, they have been noncompliant since the year 2021
when she first applied for the program. Where are they getting the amounts that are
currently in place for eligible income limits? It does not add up. It does not make
sense. If they are asking that applicants pay the funds back, then where is all the
money from the federal block grants and state funds going? Where are the funds?
V. Untimeliness of Filing Plaintiff’s Petition
The defendant’s council claims that the plaintiff lacks subject matter
jurisdiction and standing due to her untimeliness of filing her brief. The plaintiff
requested administrative review on February 3, 2024. She never received any
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correspondence regarding the administrative review. She requested another one on
February 17, 2024. After not hearing about it or receiving any correspondence, she
called 211 on March 19, 2024, and was told by the representative that it had been
completed. It was then that the representative emailed her a copy of the letter with
the administrative decision dated February 29, 2024. However, it also shows that
the administrative review decision letter wasn’t filed until March 11, 2024. Even
though the plaintiff didn’t receive the administrative review decision until March
19, 2024, she still submitted her petition for judicial review exactly 30 days from
the date of the decision letter on March 29, 2024. The plaintiff apparently forgot to
sign it and forgot to submit to her waiver of court fees. So, the district clerk
returned the filing asking her to sign the petition and submit her waiver of court
fees. The plaintiff did so and resubmitted the filing.
From this point, it is unclear what is going on with the petition. The plaintiff
originally submitted the petition for review on March 29, 2024, at 11:22 p.m. It
was not accepted. However, it was assigned a case number at that time. The filing
was then returned the following Tuesday, April 2, 2024 at 2:32 p.m. The next
filing date suggests that the plaintiff then filed the petition for review on May 13,
2024, submitted at 12:39 a.m. and then accepted at 4:26 p.m. This suggests that it
took the plaintiff another 41 days to file the petition. The plaintiff only needed to
sign the petition and submit the court fee waiver. There is no way it took her 41
days to do that and resubmit the petition. This raises a “red flag” for the plaintiff.
There are a few other issues in question. One is that the petition supposedly
submitted on May 13, 2024 at 12:39 a.m. and accepted at 4:26 p.m., is filed
marked accepted on May 13, 2024, at 11:22 p.m., which is the exact same time she
submitted the original petition for review on March 29, 2024, and definitely not the
same time the document was submitted and/or accepted on May 13, 2024. Next, on
the email that was sent to the plaintiff after the filing was returned, it showed that
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the returned reason was that the filer requested the return. The plaintiff did not
request a return.
While reviewing the envelope details on the Texas e-file website from the
file submission on March 29, 2024, it shows that the petition was submitted on
March 29, 2024, but the case was initiated on 5/13/2024. The majority of the time,
on the Texas e-file website, when a filing needs simple correction, it will retain the
original file stamped date. In this case, although the case was initiated on May 13,
2024, it retained the file mark of March 29, 2024. The fact that the file stamped
accepting time is different than the actual time it was accepted could simply be an
administrative error by the e-file system. But the plaintiff can’t seem to overlook
the coincidence of the matching file stamp times of the original filing on March 29,
2024 and May 13, 2024 of 11:22 p.m. The file stamp on May 13, 2024, was
manually placed at the exact time of 11:22 p.m. The file stamp dates and times can
manually be adjusted by the court clerks. The question is “why?” though.
Lastly, the plaintiff would like to state that she was unprepared to supply
evidence regarding the untimeliness of her petition filing during the hearing on
January 23, 2025, with the Honorable Judge Eiserloh, because she was unaware
that there was an issue with the timing of the filing of her petition for judicial
review. She was, in fact, confused by the statement, because she did file it on time.
However, she did mention Rule 2300 in the Texas Fair and Fraud Hearings
Handbook, during the hearing which states “A request for procedural review will
be considered timely if filed after 30 days when the appellant demonstrates good
cause for the filing delay.” Also, there is the option of equitable tolling for an
extended deadline due to the fact that this case is subject to judicial review for
government misconduct of state officials acting in their individual roles/capacities.
However, Judge Eiserloh made the motion to dismiss the case. After the
final judgement was issued, the Plaintiff filed both a Motion to Reinstate and a
19
Case No. 15-25-00008-CV Appellant Reply Brief
Motion for Reconsideration that included evidence that the petition was correctly
filed on time. Again, the plaintiff never received a response to her motions or
evidence and was denied her civil right of procedural due process.
Although the filing retains its original file date, it is clear that the file stamp
has undergone administrative errors and manual adjustment or tampering by
someone, possibly a clerk, which is probable cause for an investigation pursuant to
Texas Penal Code § 37.10 and § 39.02.
20
Case No. 15-25-00008-CV Appellant Reply Brief
Conclusion
As, a recipient of the neglectful effects caused by the actions displayed by
Defendants Hearings Officer Juan Rodriguez, Hearings Director Wendy Proctor,
and Administrative Judge Julia Murray, Appellant, Linda D. Tanner, Pro Se, does
have legal standing and subject matter jurisdiction to bring this case to the 459th
Judicial District Court in Travis County, Texas for judicial review. Her petition
was filed within deadline requirements and sovereign immunity is waived with
respect to U.S. Code Title 42 § 1983 and the state officials in their individual
capacities.
However, with that said and pursuant to the Voidness Doctrine, any
dismissal that is due to lack of subject matter jurisdiction is considered null and
void because a court without jurisdiction has no legal authority to rule on the case.
Judgments issued without jurisdiction are legally null and unenforceable.
21
Case No. 15-25-00008-CV Appellant Reply Brief
Prayer
Appellant, Linda D. Tanner, Pro Se, prays that the Court will motion for a
retrial for this cause in appeal. She prays that they will see that she did have
subject matter jurisdiction and legal standing to bring forth this case to the 459 th
Judicial District Court, Travis County, Texas. She prays they understand that a
dismissal made in a court without jurisdiction is considered void and will appoint
her case to the correct court. She prays that the state officials be held accountable,
in their individual capacities, for their actions of not using the correct income
limits to determine eligibility and being in state and federal noncompliance of the
clearly set and established laws for the TANF Cash Help Program. The appellant
also prays to receive the TANF Cash Help benefits that she has been unlawfully
denied six times since 2021 and to have permanent injunctive relief from being
consistently mistreated and misevaluated for the program. She also prays for
declaratory relief.
Respectfully Submitted,
——————————
Linda D. Tanner
Pro Se
Lulu143134143@gmail.com
2121 Handley Drive
Apt 51
Fort Worth, TX 76112
817-204-8004
22
Case No. 15-25-00008-CV Appellant Reply Brief
Certificate of Compliance
Pursuant to TEX. R. APP. P. 38.3, I hereby certify that this Appellant Reply
Brief contains 5,486 words. This is a computer-generated document created in
Microsoft Word, using 14-point typeface for all text, except for footnotes, which
are in 12-point typeface. In making this certificate of compliance, I am relying on
the word count provided by the software used to prepare the document.
/s/———————————
Linda D. Tanner / Pro Se
23
Case No. 15-25-00008-CV Appellant Reply Brief
Certificate of Service
This is to certify that the forgoing Appellant Reply Brief has been submitted via
the Texas E-filing website in compliance with the TEX. R. APP. P. Rule 9.5 on
June 13, 2025, to the Clerk of Court and served on all registered counsel of record.
Giselle Ortiz Astacio
Texas State Bar No. 24103222
Lauren McGee
Texas State Bar No. 24128835
Susan Millsapps
Assistant Attorney General
Office of the Attorney General of Texas
Administrative Law Division
P.O. Box 12548, Capitol Station
Austin, TX 78711-2548
Telephone: (512) 475-4200
Griselle.OrtizAstacio@oag.texas.gov
Lauren.McGee@oag.texas.gov
susan.millsapps@oag.texas.gov
/s/————————————
Linda D. Tanner / Pro Se
24
Case No. 15-25-00008-CV Appellant Reply Brief
Appendix
1. First Page of the Original Petition filed in Trial Court showing file stamp
2. Emails from the Texas E-Filing website showing timestamps of submitted
and returned petition
3. Emails from the Texas E-Filing website showing timestamps of submitted
and accepted petition and court fee waiver
4. TANF Cash Help Denial Letters from the Texas HHSC & My Texas
Benefits
25
TEXAS HEALTH AND HUMAN SERVICES
P O BOX 149029
AUSTIN, TEXAS 78714-9029
Date: 06/03/2024 Need help?
Case Number: Your text here 95
1000212693 Call 2-1-1 or 1-877-541-7905
If you have a hearing or speech disability,
call 7-1-1 or any relay service.
All numbers are free to call.
LINDA D TANNER
Your text here 4
UNIT 203
Your text hereST3
2320 POPLAR
Your
FORTtext hereTX
WORTH 2 76102-6638
Notice about your case:
SNAP Food Benefits
EDG number: Your text here 5
77205287
Who gets SNAP Food Benefits
Name Date Monthly Amount
Linda D Tanner; Your text
Sophia here 6Moreno-jaquez;
Eleanor
07/01/2024 - 10/31/2024 Your$text here 10
382.00
Your
Laylatext here
Grace 7
Tanner
Linda D Tanner; Your text
Sophia here 8Moreno-jaquez;
Eleanor Your$text here 11
05/01/2024 422.00
Your
Laylatext here
Grace 9
Tanner
Notes:
Your SNAP benefits will be available by the 25th of each month. (If this is your first time getting benefits,
you may get them early for the first few months.)
TANF cash help for families
EDG number: Your text here 94
641562132
Who can’t get TANF cash help for families
Name Date
Linda D Tanner; Your text
Sophia here 12
Eleanor Moreno-jaquez; Layla Grace
12/02/2023
Your text
Tanner here 13
Reason:
Form TF0001 Page 1 of 3
04/2024
You are not eligible for benefits. - (TW A-2350, 1 TAC 372.1001)
You didn't go to the workforce orientation. - (TW A-2214, 1 TAC 372.1253, 45 CFR 261.10)
The money you get is more than allowed by program rules. - (TW A-1341, 1 TAC 372.408)
Notes:
Linda D Tanner has used 0 months out of the 12 months allowed under State rules.
Linda D Tanner has used 0 months out of the 60 months allowed under TANF Basic rules.
Linda D Tanner has used 0 months out of the 60 months allowed under State Program rules.
Your
Monthly Income Limit for Your Household Size - EDG Number: text here 18
641562132
December 2023 - $ 188.00
Health Care Benefits
Who gets health care benefits
Name EDG number Program Date
Your text here 14 11/01/2023 -
Linda D Tanner 643472407 Medicaid
11/30/2023
07/01/2024 -
Your text
Sophia here 17
Eleanor Moreno-jaquez 705732588 Transitional Medicaid
06/30/2025
07/01/2024 -
Your
Layla text
Gracehere 15
Tanner 705732589 Transitional Medicaid
06/30/2025
12/01/2023 -
Your text
Linda here 16
D Tanner 706140896 Transitional Medicaid
06/30/2025
Form TF0001 Page 2 of 3
04/2024
TEXAS HEALTH AND HUMAN SERVICES
P O BOX 149029
AUSTIN, TEXAS 78714-9029
Date: 01/30/2025 Need help?
Case Number: Your text here 93
1000212693 Call 2-1-1 or 1-877-541-7905
If you have a hearing or speech disability,
call 7-1-1 or any relay service.
All numbers are free to call.
LINDA D TANNER
Your text here 19
APT 51
Your text hereDR
2121 HANDLEY 20
Your
FORTtext hereTX
WORTH 2176112-5140
Notice about your case:
SNAP Food Benefits
EDG number:Your text here 30
77205287
Who gets SNAP Food Benefits
Name Date Monthly Amount
Your
Laylatext here
Grace 22 Linda D Tanner;Your
Tanner; text here 24
Sophia
03/01/2025 - 04/30/2025
Your text here 28 Your$text here 25
591.00
Your textMoreno-jaquez
Eleanor here 23
Notes:
Your SNAP benefits will be available by the 25th of each month. (If this is your first time getting benefits,
you may get them early for the first few months.)
TANF cash help for families
EDG number: Your text here 92
641562132
Who can’t get TANF cash help for families
Name Date
Linda D Tanner; Your text
Sophia here 26
Eleanor Moreno-jaquez; Layla Grace
01/30/2025
Your text here 27
Tanner
Reason:
You are not eligible for benefits. - (TW A-2350, 1 TAC 372.1001)
The money you get is more than allowed by program rules. - (TW A-1341, 1 TAC 372.408)
Form TF0001 Page 1 of 3
04/2024
Notes:
Linda D Tanner has used 0 months out of the 12 months allowed under State rules.
Linda D Tanner has used 0 months out of the 60 months allowed under TANF Basic rules.
Linda D Tanner has used 0 months out of the 60 months allowed under State Program rules.
Monthly Income Limit for Your Household Size - EDG Number:Your text here 29
641562132
January 2025 - $ 188.00
Comments: After certification, TANF individuals must remit to the OAG all child support payments received
for a certified child. Individuals should be given sufficient copies of Form H1710, Payment Identification,
and OAG self-addressed envelopes, if payments are being made or might be made. When the individual
receives a child support payment from an absent parent following certification, the individual must:
write on the check or money order "Deposit Only - State Treasury" and not endorse the check or money
order;
include Form H1710 with the check or money order; and
send it to the Texas Child Support Disbursement Unit, P.O. Box 659791, San Antonio, Texas 78265-9941.
If child support is intended for a child on TANF and one on Supplemental Security Income (SSI), the
individual must remit the payment to the OAG for proration and distribution to occur.
Health Care Benefits
Who gets health care benefits
Name EDG number Program Date
Your text here 31 03/01/2025 -
Sophia Eleanor Moreno-jaquez 705732588 Transitional Medicaid
06/30/2025
03/01/2025 -
Your
Layla text here
Grace 32
Tanner 705732589 Transitional Medicaid
06/30/2025
03/01/2025 -
Your
Lindatext here 33
D Tanner 706140896 Transitional Medicaid
06/30/2025
Form TF0001 Page 2 of 3
04/2024
TEXAS HEALTH AND HUMAN SERVICES
P O BOX 149029
AUSTIN, TEXAS 78714-9029
Date: 09/21/2021 Need help?
Case Number: Your text here 90
1000212693 Call 2-1-1 or 1-877-541-7905
If you have a hearing or speech disability,
call 7-1-1 or any relay service.
All numbers are free to call.
LINDA D TANNER
Your
SUITEtext
360 here
#311 34
Your text hereSTREET
6080 S HULEN 35
Your
FORT text
WORTHhereTX3676132-6043
Notice about your case:
TANF cash help for families
EDG number:Your text here 91
641562132
Who can’t get TANF cash help for families
Name Date
Your text
Linda D Tanner; Sophia here 37
Eleanor Moreno-jaquez; Layla Grace
Your text here 38 09/15/2021
Tanner
Reason:
You are not eligible for benefits. - (TW A-2350, 1 TAC 372.1001)
The value of the things you are paying for or own are more than allowed by program rules. - (TW A-1220, 1
TAC 372.354)
The money you get is more than allowed by program rules. - (TW A-1341, 1 TAC 372.408)
Notes:
Linda D Tanner has used 0 months out of the 12 months allowed under State rules.
Linda D Tanner has used 0 months out of the 60 months allowed under TANF Basic rules.
Linda D Tanner has used 0 months out of the 60 months allowed under State Program rules.
Monthly Income Limit - EDG Number: Your text here 39
641562132
September 2021 - $ 188.00
Form TF0001/03/2021 Page 1 of 4
Health Care Benefits
Who gets health care benefits
Name EDG number Program Date
11/01/2021 -
Your text
Sophia here 40
Eleanor Moreno-jaquez 705732588 Transitional Medicaid
06/30/2022
11/01/2021 -
Your
Laylatext here
Grace 41
Tanner 705732589 Transitional Medicaid
06/30/2022
Your 11/01/2021 -
Linda text here 42
D Tanner 706140896 Transitional Medicaid
06/30/2022
Notes:
A federal public health emergency was declared on Jan. 27, 2020, which allows your Medicaid coverage to
continue for the duration of the federally declared emergency. Since the federal public health emergency
has been extended, HHSC will continue your coverage until the public health emergency ends. You are
getting this notice because a review of your most recent information indicates you will not be eligible for
Medicaid coverage when the public health emergency ends. Your Medicaid coverage will end the last day
of the month in which the public health emergency ends. While you have coverage, you should continue to
report any changes and HHSC will review your eligibility based on the changes you report.
The federal public health emergency declared January 27, 2020 and current federal guidance has allowed
certain Medicaid coverage to continue. If there are any additional changes to Medicaid coverage HHSC will
let clients know at the appropriate time.
Who can’t get health care benefits
Name EDG Number Program Date
Your
Laylatext here
Grace 43
Tanner 672828796 Children's Medicaid 06/01/2021
Your text
Sophia here 44
Eleanor Moreno-jaquez 680262146 Children's Medicaid 06/01/2021
Your
Linda text here 45
D Tanner 643472407 Medicaid 06/01/2021
Reason:
You are not eligible for benefits. - (TW A-2350, 1 TAC 366.215; 366.311; 366.409; 366.511; 366.615;
366.711; 366.811; 366.903, 42 CFR 435.919)
Layla Grace Tanner isn't: (1) age 20 or younger, (2) age 65 or older, (3) pregnant, (4) someone with a
disability, (5) a dependent child on this case, OR (6) a child who didn't get SSI (Supplemental Security
Income) due to the August 1996 change in disability rules. - (TW A-825; A-221B 475.1.2, 1 TAC 366.307;
366.507; 366.611; 366.707; 366.807, 42 CFR 435.301)
Sophia Eleanor Moreno-jaquez isn't: (1) age 20 or younger, (2) age 65 or older, (3) pregnant, (4) someone
with a disability, (5) a dependent child on this case, OR (6) a child who didn't get SSI (Supplemental
Security Income) due to the August 1996 change in disability rules. - (TW A-825; A-221B 475.1.2, 1 TAC
366.307; 366.507; 366.611; 366.707; 366.807, 42 CFR 435.301)
Linda D Tanner isn't: (1) age 20 or younger, (2) age 65 or older, (3) pregnant, (4) someone with a disability,
(5) a dependent child on this case, OR (6) a child who didn't get SSI (Supplemental Security Income) due
to the August 1996 change in disability rules. - (TW A-825; A-221B 475.1.2, 1 TAC 366.307; 366.507;
366.611; 366.707; 366.807, 42 CFR 435.301)
Notes:
Form TF0001/03/2021 Page 2 of 4
TEXAS HEALTH AND HUMAN SERVICES
P O BOX 149029
AUSTIN, TEXAS 78714-9029
Date: 06/03/2021 Need help?
Case Number: Your text here 89
1000212693 Call 2-1-1 or 1-877-541-7905
If you have a hearing or speech disability,
call 7-1-1 or any relay service.
All numbers are free to call.
LINDA D TANNER
Your text
7100 here 46
FOURTH ST
Your text here 4779835-6043
CANUTILLO TX
Notice about your case:
TANF cash help for families
EDG number: Your text here 48
641562132
Who can’t get TANF cash help for families
Name Date
Your Grace
Layla text here 49 Sophia Eleanor Moreno-jaquez; Linda D
Tanner;
06/03/2021
Tanner
Reason:
You are not eligible for benefits. - (TW A-2350, 1 TAC 372.1001)
The value of the things you are paying for or own are more than allowed by program rules. - (TW A-1220, 1
TAC 372.354)
The money you get is more than allowed by program rules. - (TW A-1341, 1 TAC 372.408)
Notes:
Linda D Tanner has used 0 months out of the 12 months allowed under State rules.
Linda D Tanner has used 0 months out of the 60 months allowed under TANF Basic rules.
Linda D Tanner has used 0 months out of the 60 months allowed under State Program rules.
Monthly Income Limit - EDG Number:Your text here 50
641562132
June 2021 - $ 751.00
Form TF0001/03/2021 Page 1 of 3
Health Care Benefits
Who gets health care benefits
Name EDG number Program Date
07/01/2021 -
Your D
Linda text here 51
Tanner 705732587 Transitional Medicaid
06/30/2022
07/01/2021 -
Your text
Sophia here 52
Eleanor Moreno-jaquez 705732588 Transitional Medicaid
06/30/2022
07/01/2021 -
Your
Layla text
Gracehere 53
Tanner 705732589 Transitional Medicaid
06/30/2022
Notes:
The federal public health emergency declared January 27, 2020 and current federal guidance has allowed
certain Medicaid coverage to continue. If there are any additional changes to Medicaid coverage HHSC will
let clients know at the appropriate time.
Who can’t get health care benefits
Name EDG Number Program Date
Reason:
You are not eligible for benefits. - (TW A-2350, 1 TAC 366.215; 366.311; 366.409; 366.511; 366.615;
366.711; 366.811; 366.903, 42 CFR 435.919)
Individuals isn't: (1) age 20 or younger, (2) age 65 or older, (3) pregnant, (4) someone with a disability, (5)
a dependent child on this case, OR (6) a child who didn't get SSI (Supplemental Security Income) due to
the August 1996 change in disability rules. - (TW A-825; A-221B 475.1.2, 1 TAC 366.307; 366.507;
366.611; 366.707; 366.807, 42 CFR 435.301)
Form TF0001/03/2021 Page 2 of 3
TEXAS HEALTH AND HUMAN SERVICES
P O BOX 149029
AUSTIN, TEXAS 78714-9029
Date: 10/02/2023 Need help?
Case Number: Your text here 88
1000212693 Call 2-1-1 or 1-877-541-7905
If you have a hearing or speech disability,
call 7-1-1 or any relay service.
All numbers are free to call.
LINDA D TANNER
Your text here 54
APT 1202
Your text here DR
4220 LANYARD 56
Your
FORTtext hereTX
WORTH 5576106-1004
Notice about your case:
TANF cash help for families
EDG number: 641562132
Who can’t get TANF cash help for families
Name Date
Your text
Linda D Tanner; Sophia here 60
Eleanor Moreno-jaquez; Layla Grace
Your text here 59 09/17/2023
Tanner
Reason:
You are not eligible for benefits. - (TW A-2350, 1 TAC 372.1001)
The money you get is more than allowed by program rules. - (TW A-1341, 1 TAC 372.408)
Notes:
Linda D Tanner has used 0 months out of the 12 months allowed under State rules.
Linda D Tanner has used 0 months out of the 60 months allowed under TANF Basic rules.
Linda D Tanner has used 0 months out of the 60 months allowed under State Program rules.
Monthly Income Limit for Your Household Size - EDG Number:Your text here 58
641562132
September 2023 - $ 188.00
Health Care Benefits
Form TF0001 Page 1 of 3
04/2023
Who gets health care benefits
Name EDG number Program Date
Your text here 62 11/01/2023 -
Sophia Eleanor Moreno-jaquez 680262146 Children's Medicaid
06/30/2024
11/01/2023 -
Your
Layla text
Gracehere 63
Tanner 711580465 Children's Medicaid
06/30/2024
Who can’t get health care benefits
Name EDG Number Program Date
Your
Lindatext here 61
D Tanner 643472407 Medicaid 11/01/2023
Reason:
You are not eligible for benefits. - (TW A-2350, 1 TAC 366.215; 366.311; 366.409; 366.511; 366.615;
366.711; 366.811; 366.903, 42 CFR 435.919)
Linda D Tanner already gets this benefit. - (TW A-210, 1 TAC 366.203; 366.303; 366.403; 366.503;
366.603; 366.703; 366.803, 42 CFR 435.906)
Form TF0001 Page 2 of 3
04/2023
TEXAS HEALTH AND HUMAN SERVICES
P O BOX 149029
AUSTIN, TEXAS 78714-9029
Date: 05/06/2021 Need help?
Case Number: Your text here 85
1000212693 Call 2-1-1 or 1-877-541-7905
If you have a hearing or speech disability,
call 7-1-1 or any relay service.
All numbers are free to call.
LINDA D TANNER
Your
7100text
4THhere
ST 69
Your text here
CANUTILLO TX 70
79835-6043
Notice about your case:
SNAP Food Benefits
EDG number:Your text here 68
77205287
Who gets SNAP Food Benefits
Name Date Monthly Amount
Linda D Tanner; Your text
Sophia here 73
Eleanor Moreno-jaquez; Your$text here 72
Your
Laylatext here
Grace 74
Tanner Your text here
06/01/2021 65
- 10/31/2021 616.00
Linda D Tanner; Your
Layla text here
Grace 67 Sophia
Tanner; Your$text here 71
Your text here 66
Eleanor Moreno-jaquez Your text here
05/05/2021 64
- 05/31/2021 507.00
Notes:
Your text here 75
Your SNAP benefits will be available by the 12th of each month. (If this is your first time getting benefits,
you may get them early for the first few months.)
TANF cash help for families
EDG number:Your text here 77
641562132
Who can’t get TANF cash help for families
Name Date
Your
Laylatext here
Grace 76 Sophia Eleanor Moreno-jaquez; Linda D
Tanner;
05/06/2021
Tanner
Reason:
Form TF0001/03/2021 Page 1 of 3
You are not eligible for benefits. - (TW A-2350, 1 TAC 372.1001)
The value of the things you are paying for or own are more than allowed by program rules. - (TW A-1220, 1
TAC 372.354)
The money you get is more than allowed by program rules. - (TW A-1341, 1 TAC 372.408)
Notes:
Linda D Tanner has used 0 months out of the 12 months allowed under State rules.
Linda D Tanner has used 0 months out of the 60 months allowed under TANF Basic rules.
Linda D Tanner has used 0 months out of the 60 months allowed under State Program rules.
Monthly Income Limit - EDG Number:Your text here 82
641562132
May 2021 - $ 751.00
Health Care Benefits
Who gets health care benefits
Name EDG number Program Date
Your Grace
text here 83 06/01/2021 -
Layla Tanner 667708300 Children's Medicaid
08/31/2021
06/01/2021 -
Your text
Sophia here 81
Eleanor Moreno-jaquez 683004549 Children's Medicaid
08/31/2021
06/01/2021 -
Your D
Linda text here 80
Tanner 599338929 Medicaid
12/31/2021
Who can’t get health care benefits
Name EDG Number Program Date
Your
Lindatext here 79
D Tanner 705050720 Children's Medicaid 06/01/2021
Reason:
You are not eligible for benefits. - (TW A-2350, 1 TAC 366.215; 366.311; 366.409; 366.511; 366.615;
366.711; 366.811; 366.903, 42 CFR 435.919)
(Linda D Tanner, Sophia Eleanor Moreno-jaquez, Layla Grace Tanner) isn't: (1) age 20 or younger, (2)
age 65 or older, (3) pregnant, (4) someone with a disability, (5) a dependent child on this case, OR (6) a
child who didn't get SSI (Supplemental Security Income) due to the August 1996 change in disability rules.
- (TW A-825; A-221B 475.1.2, 1 TAC 366.307; 366.507; 366.611; 366.707; 366.807, 42 CFR 435.301)
Form TF0001/03/2021 Page 2 of 3
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Envelope ID: 101973141
Filing Code Description: Response
Filing Description: APPELLANT REPLY BRIEF AND APPENDIX
Status as of 6/13/2025 7:07 AM CST
Associated Case Party: LindaDTanner
Name BarNumber Email TimestampSubmitted Status
Linda Tanner Lulu3822@gmail.com 6/13/2025 6:44:58 AM SENT
LINDA DTANNER lulu143134143@gmail.com 6/13/2025 6:44:58 AM SENT
Associated Case Party: JUAN RODRIGUEZ
Name BarNumber Email TimestampSubmitted Status
LAUREN MCGEE Lauren.Mcgee@oag.texas.gov 6/13/2025 6:44:58 AM SENT
GRISELLE ORTIZASTACIO Griselle.OrtizAstacio@oag.texas.gov 6/13/2025 6:44:58 AM SENT
Associated Case Party: WENDY PROCTOR
Name BarNumber Email TimestampSubmitted Status
LAUREN MCGEE Lauren.Mcgee@oag.texas.gov 6/13/2025 6:44:58 AM SENT
GRISELLE ORTIZASTACIO Griselle.OrtizAstacio@oag.texas.gov 6/13/2025 6:44:58 AM SENT
Associated Case Party: JULIA MURRAY
Name BarNumber Email TimestampSubmitted Status
LAUREN MCGEE Lauren.Mcgee@oag.texas.gov 6/13/2025 6:44:58 AM SENT
GRISELLE ORTIZASTACIO Griselle.OrtizAstacio@oag.texas.gov 6/13/2025 6:44:58 AM SENT
Associated Case Party: TEXAS HEALTH AND HUMAN SERVICES COMMISSION
Name BarNumber Email TimestampSubmitted Status
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Envelope ID: 101973141
Filing Code Description: Response
Filing Description: APPELLANT REPLY BRIEF AND APPENDIX
Status as of 6/13/2025 7:07 AM CST
Associated Case Party: TEXAS HEALTH AND HUMAN SERVICES COMMISSION
Name BarNumber Email TimestampSubmitted Status
GRISELLE ORTIZASTACIO Griselle.OrtizAstacio@oag.texas.gov 6/13/2025 6:44:58 AM SENT
ATTN: LEGAL DEPARTMENT legaldepartment@hhsc.gov 6/13/2025 6:44:58 AM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Christian Young christian.young@oag.texas.gov 6/13/2025 6:44:58 AM SENT
SUSAN MILSAPPS susan.millsapps@oag.texas.gov 6/13/2025 6:44:58 AM SENT