Monitoring the Session

SB 2215

Campbell’s bill lets residents sue cities over zoning

Did not pass

Verdict: No flags

No flagsInitial review
Sen. Donna CampbellRSenate 25

Initial review · graded Oct 22, 2026 · Headline, summary and grade are analysis of the bill text, not a finding about any person · How we grade

Caption

relating to the enforcement against violations by a municipality of certain zoning laws.

Caption from analyzed text · version H.

Summary

City immunity gone. The winner can get attorney’s fees.

The bill lets any person affected or harmed by a city's violation of the state zoning law chapter sue the city for a court order, a declaration, or an injunction. It removes the city's immunity from those lawsuits and lets the judge award court costs and attorney's fees to whichever side wins. It applies to past violations too, but does not reopen cases already decided, and it starts September 1, 2025.

Labels

Labels: QUICK READ: 124 WORDS. The bill as filed runs 124 words, counting the existing law it amends and the text it strikes. The median 89R bill as filed runs 441 words (derived, 8,702 graded bills, snapshot Oct 19, 2026).GOT HALFWAY. Passed the Senate on May 15, 2025. Died in the House: voted out of the Land & Resource Management committee 7-0, no floor vote.

Receipt

The receipt

89R-SB2215 · 2025-03-11

SOLD BY

ITEM

relating to the enforcement against violations by a municipality of certain zoning laws.

WHAT IT DOES

City immunity gone. The winner can get attorney’s fees.

The bill lets any person affected or harmed by a city's violation of the state zoning law chapter sue the city for a court order, a declaration, or an injunction. It removes the city's immunity from those lawsuits and lets the judge award court costs and attorney's fees to whichever side wins. It applies to past violations too, but does not reopen cases already decided, and it starts September 1, 2025.

CHARGES

[ ] NONE FOUND

TOTAL

No significant fiscal implication to the State is anticipated.

LBB estimate · fiscal note version H · source

Sources

Fiscal note · version H · May 22, 2025

No first-year general revenue figure available here.

LBB published estimates · flow over the stated periods.

Source snapshot 2026-10-19, Central time.

HISTORY

  1. Received by the Secretary of the Senate
  2. Filed
  3. Read first time
  4. Referred to Local Government
  5. Scheduled for public hearing on . . .
  6. Considered in public hearing
  7. Testimony taken in committee
  8. Vote taken in committee
  9. Reported favorably as substituted
  10. Committee report printed and distributed
  11. Placed on intent calendar
  12. Rules suspended-Regular order of business
  13. Record vote
  14. Read 2nd time & passed to engrossment
  15. Record vote
  16. Three day rule suspended
  17. Record vote
  18. Read 3rd time
  19. Passed
  20. Record vote
  21. Reported engrossed
  22. Received from the Senate
  23. Read first time
  24. Referred to Land & Resource Management
  25. Posting rule suspended
  26. Scheduled for public hearing on . . .
  27. Considered in public hearing
  28. Committee substitute considered in committee
  29. Testimony taken/registration(s) recorded in committee
  30. Left pending in committee
  31. Considered in formal meeting
  32. Committee substitute considered in committee
  33. Reported favorably as substituted
  34. Comte report filed with Committee Coordinator
  35. Committee report distributed
  36. Committee report sent to Calendars
  37. Considered in Calendars
  38. Placed on General State Calendar
FILED UNDER

No verified beat found.

SIGNED FOR BY

Senate · 23 yea · 8 nay

Sources

Senate: Final passage · May 15, 2025. Journal. Published stock for this vote. Snapshot 2026-10-19, Central time.

All floor motions and other positions below.

No flags

THANK YOU FOR CHECKING THE RECEIPT

CAMPAIGN PAID FOR BY

CAMPAIGN PAID FOR BY

Donors

Donors report through Friends of Donna Campbell.

Not tied to this bill.

Sources

The author's campaign account only. Own money and internal transfers are separate on the member page.

Derived itemized flow · Oct 27, 2024 to Jun 30, 2026. State data as of Nov 4, 2026.

Derived itemized contributions on live regular reports and uncovered special-session dates. Internal account transfers and daily reports are excluded.

Money

Missing data does not establish zero giving. Display amounts are rounded.

Votes4

Senate May 15, 2025

Yea
23
Nay
8
Present, not voting
Not printed
Absent
0
Excused
0
Names

Named positions matched to lawmakers. See the journal for unmatched names.

Senate journal

Sources

The bill was read third time and was passed by the following vote: Yeas 23, Nays 8.

Published stock of positions for this vote, except where marked derived.

  • Yea: 23 (published)
  • Nay: 8 (published)
  • Present, not voting: Not printed
  • Absent: 0 (derived from named list)
  • Excused: 0 (derived from named list)

Senate journal. Source snapshot 2026-10-19, Central time.

Senate May 15, 2025

Yea
25
Nay
6
Present, not voting
Not printed
Absent
0
Excused
0
Names

Named positions matched to lawmakers. See the journal for unmatched names.

Senate journal

Sources

Senator Campbell moved that Senate Rule 7.18 and the Constitutional Rule requiring bills to be read on three several days be suspended and that CSSB 2215 be placed on its third reading and final passage: CSSB 2215, Relating to the enforcement against violations by a municipality of certain zoning laws. The motion prevailed by the following vote: Yeas 25, Nays 6.

Published stock of positions for this vote, except where marked derived.

  • Yea: 25 (published)
  • Nay: 6 (published)
  • Present, not voting: Not printed
  • Absent: 0 (derived from named list)
  • Excused: 0 (derived from named list)

Senate journal. Source snapshot 2026-10-19, Central time.

Senate May 15, 2025

Yea
22
Nay
9
Present, not voting
Not printed
Absent
0
Excused
0
Names

Named positions matched to lawmakers. See the journal for unmatched names.

Senate journal

Sources

The bill was read second time and was passed to engrossment by the following vote: Yeas 22, Nays 9. (Same as previous roll call)

Published stock of positions for this vote, except where marked derived.

  • Yea: 22 (published)
  • Nay: 9 (published)
  • Present, not voting: Not printed
  • Absent: 0 (derived from named list)
  • Excused: 0 (derived from named list)

Senate journal. Source snapshot 2026-10-19, Central time.

Senate May 15, 2025

Yea
22
Nay
9
Present, not voting
Not printed
Absent
0
Excused
0
Names

Named positions matched to lawmakers. See the journal for unmatched names.

Senate journal

Sources

Senator Campbell moved to suspend the regular order of business to take up for consideration CSSB 2215 at this time on its second reading: CSSB 2215, Relating to the enforcement against violations by a municipality of certain zoning laws. The motion prevailed by the following vote: Yeas 22, Nays 9.

Published stock of positions for this vote, except where marked derived.

  • Yea: 22 (published)
  • Nay: 9 (published)
  • Present, not voting: Not printed
  • Absent: 0 (derived from named list)
  • Excused: 0 (derived from named list)

Senate journal. Source snapshot 2026-10-19, Central time.

Witnesses16
For
9
Against
7
On
0
Names

For

  • Self3 registrations
  • Self; Lambeth building company1 registration
  • Texas Association of Builders3 registrations
  • Texas Farm Bureau2 registrations

Against

  • City of Garland, Texas1 registration
  • City of San Antonio2 registrations
  • Self2 registrations
  • Texas Municipal League2 registrations
Sources

16 parsed registrations across the loaded witness lists.

Derived stock of witness registrations. Repeated appearances count separately. Organizations and self-representation appear as printed.

House witness list. Source snapshot 2026-10-20, Central time.

Senate witness list. Source snapshot 2026-10-20, Central time.

Fiscal

No significant fiscal implication to the State is anticipated.

LBB estimate · fiscal note version H · source

Sources

Fiscal note · version H · May 22, 2025

No first-year general revenue figure available here.

LBB published estimates · flow over the stated periods.

Source snapshot 2026-10-19, Central time.

How this was graded

Analysis of text version H by claude-opus-5-5, Oct 22, 2026, against the published rubric.

Sources

Texas Senate · Filed Mar 11, 2025

05/26/2025 H Placed on General State Calendar

Texas Legislature Online · Introduced · Senate Committee Report · Engrossed · House Committee Report

Data snapshot Oct 26, 2026 at 4:20 AM CDT. Grades, charges, quotes and corrections follow the published record.

Sponsors

House committee · Land & Resource Management · Committee vote 7 aye, 0 nay, 2 absent · Out of committee

Senate committee · Local Government · Committee vote 4 aye, 1 nay, 2 absent · Out of committee

Subjects

City Government--Land Use & Zoning

Property Interests--Real Property

Text

The text as introduced · 124 words

By: Campbell
S.B. No. 2215

A BILL TO BE ENTITLED

AN ACT

relating to the right of property owners to challenge municipal

zoning regulations and boundaries.

BE IT ENACTED BY THE LEGISLATURE OF THE STATE OF TEXAS:

SECTION 1. Subchapter A, Chapter 211, Local Government Code

is amended by adding Sections 211.020 to read as follows:

Sec. 211.020. ENFORCEMENT OF CHAPTER. (a) This chapter may

be enforced only through mandamus or declaratory or injunctive

relief.

(b) A political subdivision's immunity from suit is waived

in regard to an action under this chapter.

(c) A court may award court costs and reasonable and

necessary attorney's fees to the prevailing party in an action

under this chapter.

SECTION 2. This Act takes effect September 1, 2025.