"Remedies, Not Claims": The Texas Supreme Court Reframes the Redundant-Remedies Doctrine in Gonzalez v. Texas Medical Board

I. Introduction

The Supreme Court of Texas’s opinion in Reynaldo "Rey" Gonzalez, Jr., M.D., J.D. v. Texas Medical Board sits at the intersection of administrative law, constitutional litigation strategy, and professional regulation of political speech. At its core, the Court does not decide whether the Texas Medical Board (TMB) may constitutionally punish a political candidate for calling himself “Dr.” or “physician” when he holds an M.D. but no medical license. Instead, the Court resolves threshold jurisdictional and remedial issues that determine how, and in what procedural posture, those constitutional questions will be litigated.

The decision is particularly significant for three reasons:

1. It clarifies and sharpens the redundant-remedies doctrine under the Uniform Declaratory Judgments Act (UDJA), holding that courts must ask whether the remedies available in an administrative-review action duplicate those sought in a UDJA suit — not merely whether the claims could have been raised there.
2. It reaffirms that agency rules cannot create district-court jurisdiction for judicial review of agency orders in the absence of a statutory grant.
3. It clears the way for a full merits adjudication of both facial and as-applied constitutional challenges (and an ultra vires claim) to TMB’s attempt to regulate campaign speech, thus setting the stage for an important First Amendment and Texas free-speech ruling down the line.

The case involves a lawyer–physician (degree-holder, but non-licensee) candidate for Congress, a state medical board historically focused on clinical practice rather than political messaging, and statutes that purport to regulate who may publicly represent themselves as a “doctor” or “physician.” The opinion is procedurally focused but has substantial substantive implications.

II. Background and Procedural History

A. Factual Background

Reynaldo “Rey” Gonzalez, Jr. holds both a medical degree (M.D.) and a law degree (J.D.). He chose to practice law rather than medicine, teaching as an adjunct professor at the University of Texas and participating in the American Board of Legal Medicine. He is licensed to practice law, but has never been licensed to practice medicine in Texas.

While running for a seat in the United States House of Representatives, Gonzalez:

• referred to himself as “Dr. Gonzalez,”
• described himself as a “physician,” and
• published campaign material stating: “By God's grace I am a physician and an attorney,” explaining his callings “to heal” in medicine, law, and public office.

A complaint was filed with the Texas Medical Board alleging that Gonzalez was falsely holding himself out as a physician and improperly calling himself “Dr. Gonzalez.” TMB opened an investigation into whether his campaign communications constituted the unlicensed practice of medicine.

After a hearing, TMB concluded that Gonzalez had violated the Medical Practice Act and the Healing Art Identification Act (specifically, Texas Occupations Code § 104.004) and issued a cease-and-desist order. The order:

• prohibited Gonzalez from using the titles “doctor,” “physician,” or “Dr.” (as in “Dr. Gonzalez”) unless he clearly designated the authority giving rise to those titles; and
• effectively required him to disclose in campaign materials (and perhaps oral statements) that he held an M.D. but was not licensed to practice medicine.

Noncompliance with the order would expose Gonzalez to civil penalties of $5,000 per violation. After his motion for rehearing was overruled by operation of law, Gonzalez filed suit in Travis County district court 81 days later.

B. Gonzalez’s Claims in the Trial Court

Gonzalez’s “many” claims distill into four principal theories, as the Supreme Court summarizes:

1. The cease-and-desist order was not supported by substantial evidence (a classic administrative-law claim).
2. Texas Occupations Code § 104.004 is unconstitutional as applied to his campaign speech.
3. Section 104.004 is facially unconstitutional because it prevents persons with medical or other doctoral degrees from truthfully describing their education and training.
4. The Texas Medical Board exceeded its statutory authority (an ultra vires claim) by regulating him even though he is not licensed to practice medicine and did not in fact practice or attempt to practice medicine.

He sought:

• reversal of the cease-and-desist order,
• declarations that TMB lacked statutory authority and/or that § 104.004 was unconstitutional,
• temporary injunctive relief against enforcement of the cease-and-desist order, and
• “such other and further equitable relief” to which he was entitled.

C. Lower Courts’ Dispositions

TMB challenged subject-matter jurisdiction. The district court dismissed all claims for want of jurisdiction. The Third Court of Appeals (Austin) largely affirmed, with one important exception:

• It held that Gonzalez’s facial constitutional challenge to § 104.004 could proceed because a declaration that the statute is facially unconstitutional would “go beyond reversal” of the cease-and-desist order and thus was not barred by the redundant-remedies doctrine.
• It held that Gonzalez’s as-applied constitutional claim and his ultra vires claim were barred as redundant, because he could have raised these challenges in a timely petition for judicial review under the Texas Administrative Procedure Act (APA).
• It treated the cease-and-desist proceedings as a “contested case” under the APA and concluded that his substantial-evidence challenge was untimely under the APA’s 30-day deadline for judicial review.

Gonzalez petitioned for review in the Supreme Court of Texas. TMB did not file a cross-petition, which becomes important for the scope of the Supreme Court’s power to disturb the court of appeals’ judgment.

III. Summary of the Supreme Court’s Opinion

Justice James P. Sullivan, writing for the Court (with Justice Hawkins not participating), reverses in part, affirms in part, and remands. The Court’s holdings can be summarized as follows:

1. Redundant-remedies doctrine narrowed: The Third Court of Appeals erred in applying the redundant-remedies doctrine to dismiss Gonzalez’s as-applied constitutional and ultra vires claims. Even if those claims could have been raised in an APA judicial-review action, the APA could have provided at most reversal of the specific cease-and-desist order. Gonzalez seeks broader, prospective relief that would protect future speech; therefore, the UDJA claims are not redundant.
2. Facial constitutional claim properly remanded: The court of appeals was correct that the facial constitutional challenge is not barred by the redundant-remedies doctrine and should proceed in district court (and that portion of its judgment is not disturbed, especially since TMB filed no cross-petition).
3. Substantial-evidence claim dismissed for want of jurisdiction: The district court lacked jurisdiction over Gonzalez’s substantial-evidence challenge to the cease-and-desist order. There is no statute authorizing judicial review of such orders outside the APA, and Gonzalez affirmatively disclaimed reliance on the APA. An agency rule cannot itself create district-court jurisdiction.
4. Remand for merits: The case is remanded to the district court for proceedings on:
   • the facial constitutional challenge to § 104.004,
   • the as-applied constitutional challenge, and
   • the ultra vires claim.
   The Court explicitly states that “if the Texas Medical Board thinks it has the power to police campaign speech, it will have to defend that position on the merits.”

IV. Detailed Analysis

A. The Redundant-Remedies Doctrine Reframed

1. The Court of Appeals’ Approach

The Third Court of Appeals relied on the redundant-remedies doctrine articulated in Patel v. Texas Department of Licensing & Regulation and subsequent cases. The doctrine provides that courts will ordinarily decline to entertain a UDJA action when the same dispute can be addressed through a more specific statutory mechanism.

In the court of appeals’ view:

• Gonzalez could have sought reversal of the TMB cease-and-desist order through a timely APA petition for judicial review;
• Because his as-applied and ultra vires claims could have been raised in that APA proceeding, a UDJA action asserting them was “redundant” and thus barred;
• Only the facial constitutional claim went “beyond reversal” and so survived.

Critically, the court of appeals read Gonzalez’s petition as “challeng[ing] only the cease-and-desist order” except for the facial claim, narrowing his prayer to relief directed at that past order.

2. The Supreme Court’s Correction: The Focus Is on Remedies, Not Claims

The Supreme Court firmly rejects this reasoning and clarifies the doctrinal framework:

“What matters is whether the APA would've afforded him the same remedy—that's why we call it the redundant-remedies doctrine, not the redundant-claims doctrine.”

The Court emphasizes two linked points:

1. Petitions must be read fairly and holistically. Gonzalez’s live petition did not merely attack the specific cease-and-desist order; it also sought declarations and injunctions that would prospectively constrain TMB from regulating his campaign speech in the future on the same legal theories. Properly read, his as-applied constitutional and ultra vires claims challenge TMB’s authority to take any adverse action against his political use of “doctor” or “physician,” not only the past order.
2. The redundancy analysis turns on the scope of relief. Even if Gonzalez could have asserted the same legal claims (constitutional and ultra vires) in an APA judicial-review action, that proceeding would be limited to reversing or affirming the cease-and-desist order. It could not grant the kind of prospective, global relief he seeks to protect his ongoing and future campaign speech.

The Court cites its own decision in Patel as controlling: there, as here, litigants sought “more than a reversal of the citations issued” and sought “prospective injunctive relief against future agency orders” based on challenged statutes and rules. Under Patel, the APA did “not provide a redundant remedy” because it could not furnish this forward-looking protection.

3. Application to Gonzalez’s Claims

Applying this clarified standard, the Court draws a sharp distinction among Gonzalez’s claims:

• Facial constitutional claim: All agree this goes beyond mere reversal of the cease-and-desist order. A declaration that § 104.004 is facially unconstitutional would prohibit its enforcement against anyone in any context, not just Gonzalez in this case. The court of appeals correctly allowed this claim to proceed.
• As-applied constitutional claim: Properly construed, this seeks a declaration that applying § 104.004 to Gonzalez’s campaign speech — i.e., his political use of “doctor” and “physician” — violates the First Amendment and the Texas Constitution. That relief, too, would bind TMB going forward and prevent future enforcement against him on the same basis. Such relief cannot be fully obtained via APA review of a past order. Therefore, it is not redundant.
• Ultra vires claim: Gonzalez alleges that TMB lacked statutory authority to regulate non-licensees like him solely for political speech that does not constitute the practice or attempted practice of medicine. A declaration that TMB has no statutory authority to take adverse action against him for calling himself a doctor or physician in a campaign would have obvious prospective effect and would prevent future cease-and-desist orders or penalties on the same theory. Again, the APA cannot furnish this broad prospective relief; thus, the ultra vires claim is not barred as redundant.

Consequently, the Supreme Court holds that the court of appeals “went astray” in barring those claims and remands them for merits consideration.

B. Ultra Vires and As-Applied Constitutional Claims

1. The Nature of Ultra Vires Suits

In Texas, sovereign immunity generally bars suits against the State and its agencies, but there is a well-established carveout for ultra vires actions: suits that allege state officials acted without legal authority or failed to comply with mandatory statutory or constitutional requirements.

The Court relies on City of El Paso v. Heinrich for the rule that ultra vires suits:

• must be brought against state actors in their official capacity, not the agency as such;
• can proceed despite sovereign immunity because, conceptually, an act beyond lawful authority is not the act of the State; and
• ordinarily seek only prospective relief (injunctions or declarations), not damages.

The opinion notes that on remand Gonzalez will be free to amend his pleadings, including:

• adding explicit claims for prospective constitutional relief, and
• naming appropriate state officials in their official capacities rather than (or in addition to) the TMB as an entity.

This underscores that the Court is focused on structure and form as much as substance: it indicates how a plaintiff challenging agency overreach should properly frame an ultra vires suit to avoid sovereign-immunity barriers and to secure forward-looking protection.

2. As-Applied Constitutional Claims and Litigation Sequence

The opinion also gestures toward an important doctrinal sequencing principle: as the Court notes (citing King Street Patriots v. Texas Democratic Party and the U.S. Supreme Court’s decision in Board of Trustees v. Fox), the “usual judicial practice” is to consider an as-applied constitutional challenge before addressing a facial challenge.

By remanding both types of constitutional challenges together, the Supreme Court:

• aligns the procedural posture with this usual sequencing; and
• ensures that the district court will have the opportunity to resolve the narrow, fact-specific question (is § 104.004 constitutional as applied to Gonzalez’s truthful campaign speech?) before reaching the broader, system-wide question of whether the statute is unconstitutional in all or most of its applications.

C. Judicial Review of Agency Orders and the Limits of Agency Power

1. Substantial-Evidence Review and the APA

On the substantial-evidence claim, the Court takes a different route than the court of appeals. Rather than deciding whether the cease-and-desist proceeding was a “contested case” under the APA and whether the APA 30-day deadline applied, the Court focuses on an antecedent issue: what source of jurisdiction, if any, Gonzalez invokes.

Gonzalez explicitly disclaimed reliance on the APA as the basis for judicial review. Instead, he argued that TMB itself had created a right to judicial review by promulgating a rule — former 22 Tex. Admin. Code § 187.83(f) (since repealed) — allowing a party aggrieved by a cease-and-desist order to file a petition in Travis County district court “with no deadline.”

The Supreme Court responds by restating a foundational principle of Texas administrative law (quoting Continental Casualty Insurance Co. v. Functional Restoration Associates):

“It is well recognized under Texas law that there is no right to judicial review of an administrative order unless a statute provides a right or unless the order . . . violates a constitutional right.”

Among the implications:

• No inherent right to review of agency decisions exists in Texas; judicial review must be grounded in a statute (or in a constitutional violation, which usually changes the nature of the claim—e.g., from “substantial evidence” to “constitutional challenge”).
• When a litigant explicitly rejects the APA basis for jurisdiction, he must point to some other statute authorizing review of the particular type of agency action.

Gonzalez did not identify any statute granting judicial review of TMB cease-and-desist orders independent of the APA. As a result, his substantial-evidence claim was properly dismissed for lack of jurisdiction, regardless of whether the APA might have been available (if used properly and timely).

2. Agency Rules Cannot Create Jurisdiction

The Court underscores a second key principle, again drawing on Continental Casualty:

“An agency's rulemaking power cannot validly expand or create district court jurisdiction beyond that given in the Legislature's own enactments.”

In other words:

• The Legislature, not administrative agencies, defines the jurisdiction of the courts.
• Even if an agency rule purports to authorize judicial review, that rule is juridically irrelevant to the existence of subject-matter jurisdiction unless some statute independently supports that review.

By rejecting Gonzalez’s reliance on TMB’s rule alone, the Court sends a clear message to agencies: rulemaking cannot be used either to create or to enlarge pathways to judicial review. That power rests solely with the Legislature.

3. “Contested Case” Question Left Open

The Court notes, but carefully sidesteps, an interesting question: What exactly counts as a “contested case” under the APA?

The court of appeals applied a line of precedent holding that if an agency in fact provides an adjudicative hearing, the matter is a “contested case” even if the substantive statute did not compel a hearing. The Supreme Court cites scholarship suggesting that “contested case” may have originally been understood more narrowly — referring only to proceedings where the Legislature mandates an adjudicatory hearing.

Because the Court resolves the substantial-evidence issue on jurisdictional grounds (absence of a statutory basis for review apart from the APA, which Gonzalez disclaims), it does not decide this contested-case question. But the footnote signals potential future reevaluation of the scope of the APA’s “contested case” category, an issue that could affect many agencies and regulated parties.

D. Precedents Cited and Their Role in the Court’s Reasoning

The opinion weaves several key precedents into its reasoning:

• Serafine v. Branaman, 810 F.3d 354 (5th Cir. 2016)
  The Court opens by comparing this case to Serafine, where the Fifth Circuit held that the Texas State Board of Examiners of Psychologists violated a political candidate’s First Amendment rights by forbidding her from using the title “psychologist” in her campaign. By invoking Serafine, the Texas Supreme Court:
  • underscores the unusual nature of professional boards policing campaign speech;
  • signals that Gonzalez’s free-speech concerns are serious and cognizable; and
  • sets a contextual backdrop in which TMB will have to justify its regulation of political titles under strong constitutional scrutiny.
• Patel v. Texas Department of Licensing & Regulation, 469 S.W.3d 69 (Tex. 2015)
  Patel is the anchor for the Court’s redundant-remedies analysis. There, plaintiffs challenged licensing requirements for eyebrow-threading as unconstitutional and sought forward-looking declaratory and injunctive relief under the UDJA. The State argued those claims were barred because plaintiffs could contest citations through APA review. The Texas Supreme Court rejected that argument, emphasizing that the APA’s remedies are limited to the specific orders at issue, whereas plaintiffs sought broader protection from future enforcement of unconstitutional rules.
  
  In Gonzalez’s case, the Court quotes and applies Patel to hold that the scope of remedies drives the redundancy analysis: where litigants seek prospective relief against future enforcement, the UDJA action is not redundant of APA review.
• Jones v. Turner, 646 S.W.3d 319 (Tex. 2022)
  Jones is cited for the proposition that a UDJA claim is improper only when the plaintiff could obtain relief through another mechanism that would render the declaratory judgment “redundant.” The Court reinforces the same remedial focus: not whether similar issues could be raised elsewhere, but whether another avenue gives the same effective relief.
• City of Corpus Christi v. Public Utility Commission, 51 S.W.3d 231 (Tex. 2001) (per curiam)
  This case is referenced to show that even facial constitutional challenges can be adjudicated in the course of APA judicial review of contested cases. The point is to undercut the court of appeals’ reasoning: if the mere availability of APA review barred UDJA actions, it would bar facial challenges too — which the court of appeals correctly recognized it does not. That highlights the error in focusing on “claims” instead of “remedies.”
• City of El Paso v. Heinrich, 284 S.W.3d 366 (Tex. 2009)
  Cited to explain that ultra vires suits must be brought against officials in their official capacities rather than against the governmental entity itself. This guides the form of Gonzalez’s claims on remand.
• Continental Casualty Ins. Co. v. Functional Restoration Associates, 19 S.W.3d 393 (Tex. 2000)
  Central to the substantial-evidence issue. The Court quotes its holding that judicial review of an administrative order exists only if:
  • a statute grants that right, or
  • the order violates a constitutional right.
  It also reaffirms the corollary that agencies cannot expand court jurisdiction by rulemaking.
• Chemical Bank & Trust Co. v. Falkner, 369 S.W.2d 427 (Tex. 1963)
  This decision is briefly cited to acknowledge, but not decide, the theoretical possibility of an “inherent” constitutional right to judicial review in some contexts. Gonzalez did not raise such a theory, so the Court leaves the question open.
• King Street Patriots v. Texas Democratic Party, 521 S.W.3d 729 (Tex. 2017), and Board of Trustees v. Fox, 492 U.S. 469 (1989)
  Together, these cases support the principle that courts generally address as-applied challenges before facial challenges, which undergirds the Court’s view that the court of appeals’ limited remand (facial claim only) was awkward and incomplete.

E. Free Speech, Campaign Speech, and the Regulation of Professional Titles

While predominantly procedural, the opinion unmistakably frames the case as one about political speech and governmental attempts to regulate the use of professional titles in campaigns.

Key contextual points include:

• TMB is historically tasked with regulating the practice of medicine and ensuring that practitioners are licensed and meet standards of care. Yet, as the Court notes, “there is considerably less precedent for that agency policing political campaigns,” and TMB believes this is its first disciplinary action based on campaign statements.
• Gonzalez’s statements — that he is a “physician” and “Dr. Gonzalez” and that he is “called to heal” — are framed as truthful descriptions of his education and training (he does have an M.D.), albeit without a current medical license.
• The cease-and-desist order effectively demands that he either:
  • stop using “doctor” and “physician” in campaign communications, or
  • add clarifying disclosures in his materials and even speeches, identifying himself as an M.D. but not a licensed physician.

By closing with the statement that if TMB “thinks it has the power to police campaign speech, it will have to defend that position on the merits,” the Court:

• signals that strong constitutional scrutiny is likely appropriate when professional boards regulate core political speech;
• places TMB’s actions against a backdrop of existing First Amendment doctrine, including cases like Serafine; and
• ensures that on remand the trial court must robustly confront the First Amendment and Texas Article I, § 8 issues.

The merits questions now in the queue include:

• Is it constitutional to forbid a candidate with an earned M.D. from calling himself a “doctor” or “physician” without a licensing disclaimer?
• Is such speech misleading, and if so, does that justify the restrictions?
• Does § 104.004, on its face or as applied, impermissibly burden truthful, non-misleading, political speech by degree-holders?

The Supreme Court leaves these questions to the district court but ensures that they will, in fact, be adjudicated.

V. Simplifying Key Legal Concepts

A. Facial vs. As-Applied Constitutional Challenges

• A facial challenge asserts that a statute is unconstitutional in virtually all of its applications or that it is invalid on its face. If successful, the statute is effectively inoperative in the contexts covered by the ruling.
• An as-applied challenge concedes that the statute may be valid in general but claims it is unconstitutional as applied to the plaintiff’s particular circumstances or conduct.

Courts usually prefer to resolve as-applied challenges first because they are narrower and more fact-specific, and because resolving them may obviate the need to strike down a statute entirely.

B. The Uniform Declaratory Judgments Act and the APA

Texas litigants have two primary procedural tools in disputes with agencies:

1. The Administrative Procedure Act (APA): Provides a mechanism for judicial review of specific agency orders in “contested cases.” Relief under the APA is usually limited to reversal, remand, or affirmance of that particular order, sometimes with instructions.
2. The Uniform Declaratory Judgments Act (UDJA): Allows parties to seek court declarations interpreting statutes or determining whether statutes, rules, or governmental actions are valid or constitutional. UDJA actions may also support injunctive relief.

The redundant-remedies doctrine prevents litigants from using the UDJA to duplicate the relief available through a more specific statutory process. Post-Gonzalez, the focus must be on whether the other process (here, APA review) can provide the same remedy — particularly, whether it can offer forward-looking protection against future enforcement or only backwards-looking relief concerning a specific order.

C. Substantial Evidence Review

“Substantial evidence” review is a deferential standard used by courts reviewing certain agency fact-finding. Under it, a court asks:

• Is there more than a mere scintilla of evidence supporting the agency’s decision?
• Could a reasonable mind have reached the same conclusion as the agency on the evidence presented?

In Texas, this form of review is generally available only where the Legislature has authorized it by statute — often via the APA or specific enabling acts. Without such statutory authorization (or a constitutional violation theory), courts lack jurisdiction to perform substantial-evidence review of an agency order.

D. Sovereign Immunity and Ultra Vires Claims

Sovereign immunity ordinarily shields the State and its agencies from suit. However:

• Under the ultra vires doctrine, suits may proceed against state officials in their official capacities alleging that they acted beyond their lawful authority.
• These suits typically seek prospective relief (e.g., an injunction prohibiting officials from enforcing an invalid rule), not damages.

In Gonzalez, the ultra vires claim contends that TMB officials had no statutory authority to treat Gonzalez’s campaign speech as the “practice of medicine” or to regulate his use of professional titles as a non-licensee under the Medical Practice Act and § 104.004. If correct, this would entitle him to prospective relief preventing similar future enforcement efforts.

VI. Potential Impact and Future Developments

A. Impact on Administrative and Constitutional Litigation Strategy

The decision significantly refines how litigants and courts should approach overlapping UDJA and APA remedies:

• Plaintiffs challenging agency authority or the constitutionality of statutes/regulations have clearer support for pursuing forward-looking declaratory and injunctive relief even where APA review of a past order was (or is) available.
• Courts must now explicitly examine whether the statutory review mechanism offers the same scope of relief. If it does not — especially if it is limited to reversal of a particular order — UDJA actions for prospective relief should not be dismissed as “redundant.”
• Agencies and the Attorney General will have a more difficult time using the redundant-remedies doctrine to bar UDJA suits that aim to prevent future enforcement, especially where constitutional rights are implicated.

B. Impact on Professional Licensing Boards and Regulation of Speech

Although the Court did not yet decide the merits, its framing has substantial consequences for professional boards:

• Boards must anticipate that efforts to regulate the titles and self-descriptions used in political campaigns will face intense constitutional scrutiny and cannot be insulated by procedural obstacles alone.
• Statutes like § 104.004 and similar “identification” provisions in other professions may be vulnerable to facial or as-applied challenges if they prohibit or burden truthful, non-misleading speech about an individual’s education, qualifications, or professional background, particularly in the political arena.
• The combination of Serafine and Gonzalez suggests a growing judicial skepticism toward the expansion of professional regulation into campaign speech—an area traditionally at the core of First Amendment protection.

C. Legislative and Rulemaking Responses

The opinion may prompt:

• Legislative clarification of when and how cease-and-desist orders from boards like TMB are subject to judicial review, including whether and to what extent the APA applies; and
• Reexamination of agency rules that purport to authorize judicial review or impose requirements on political speech involving professional titles, to ensure consistency with constitutional constraints and the Court’s jurisdictional holdings.

Agencies will also need to ensure that their enforcement practices do not conflate:

• the practice of a profession (e.g., medicine, psychology), and
• the use of professional degrees or titles in public discourse, especially in campaigns.

The latter is much more likely to be treated as core political speech with strong First Amendment protection.

VII. Conclusion

Gonzalez v. Texas Medical Board is a procedurally focused but substantively important decision that:

• Recalibrates the redundant-remedies doctrine, insisting that courts ask whether the alternative statutory process offers the same remedies — especially prospective protection — rather than simply whether the same claims could have been raised.
• Reaffirms that judicial review of agency orders must rest on legislative enactments or constitutional violations, and that agency rules cannot create court jurisdiction.
• Ensures that key questions about the constitutionality of regulating professional titles in political campaigns will be litigated on the merits in the trial court.

By remanding Gonzalez’s facial and as-applied constitutional challenges and his ultra vires claim, the Court opens the door to an eventual clarification of the extent to which Texas may restrict truthful references to academic and professional credentials in political speech. Whatever the ultimate merits outcome, the opinion already reshapes Texas administrative and constitutional litigation by emphasizing that where plaintiffs seek prospective, non-redundant relief, UDJA suits remain a vital and independent vehicle for judicial review.