The City of Dallas challenged the standing of the Dallas Morning News to sue for mandamus relief under the Texas Open Records Act because two Morning News reporters had made the original requests for public information, and not the Morning News itself. Noting that a "requestor" can be the Morning News acting through its agents, the Dallas Court of Appeals rejected the City’s argument and concluded that the evidence showed that the requestors made their requests in the course and scope of their position as reporters for the Morning News.
Addressing a separate issue, the court of appeals held that the trial court should have sustained the City’s plea to the jurisdiction as to the Morning News’ request for declaratory relief. Because the Morning News’ petition for writ of mandamus already encompassed the issues that were part of its request for declaratory relief, the court of appeals held that declaratory relief was not available.
Finally, the appellate court sustained an award of attorney’s fees to the Morning News because the Morning News had already substantially prevailed (in a prior appeal) on its request for relief under the Open Records Act.