Honorable Hope Andrade v. Don Venable, 372 S.W.3d 134 (Tex. 2012). · Go Syfert
Honorable Hope Andrade v. Don Venable, 372 S.W.3d 134 (Tex. 2012). Cases Citing This Book View Copy Cite
93 citation events (93 in the last 25 years) across 2 distinct courts.
Treatment trajectory · 2013 → 2026 · click a year to view as-of
2013 2019 2026
Top citers, strongest first. 36 distinct citers. How cited ↗
examined Cited as authority (verbatim quote) In Re Novartis Pharmaceuticals Corporation v. the State of Texas (3×) also: Cited as authority (rule)
Tex. App. · 2025 · quote attribution · 2 verbatim quotes · confidence high
unless standing is conferred by statute, a plaintiff must show that he has suffered a particularized injury distinct from the general public.
examined Cited as authority (verbatim quote) State of Texas v. City of San Antonio, Ron Niremberg, in His Official Capacity as Mayor of the City of San Antonio, and Erik Walsh, in His Official Capacity as City Manager of the City of San Antonio (4×) also: Cited as authority (rule)
Tex. App. · 2025 · signal: see also · quote attribution · 3 verbatim quotes · confidence high
under williams, in order to establish taxpayer standing a plaintiff must plead facts showing that the government is actually spending money on the allegedly illegal activity-not on a related legal activity.
discussed Cited as authority (verbatim quote) AIRW 2017-7, L.P.; 600 Westinghouse Investments, LLC; 800 Westinghouse Investments, LLC; Texas Commission on Environmental Quality; And Jonah Water Special Utility District v. City of Georgetown, Texas
Tex. App. · 2025 · signal: see · quote attribution · 1 verbatim quote · confidence high
the expenditure cannot be de minimis-it must be significant.
discussed Cited as authority (rule) Jane Nelson in Her Official Capacity as Secretary of State for the State of Texas v. Jarrett Woodward, Heather Couchman, Amber Cloy, Tommie Dickinson, Travis Eubanks, Amanda Eubanks, Traci Jones, Lars Kuslich, Michelle Pique, Madelon Highsmith, and Sharon Cotton, Voters of Bexar County (2×)
Tex. App. · 2025 · confidence medium
Ed. 2D 20 (1974) ........ 12 Andrade v. Venable, 372 S.W.3d 134, 137 (Tex. 2012) .................................................................. 6 Bland Indep.
cited Cited as authority (rule) Jane Nelson in Her Official Capacity as Secretary of State for the State of Texas v. Jarrett Woodward, Heather Couchman, Amber Cloy, Tommie Dickinson, Travis Eubanks, Amanda Eubanks, Traci Jones, Lars Kuslich, Michelle Pique, Madelon Highsmith, and Sharon Cotton, Voters of Bexar County
Tex. App. · 2025 · confidence medium
“Unless standing is conferred by statute, a plaintiff must show that he has suffered a particularized injury distinct from the general public.” Andrade v. Venable, 372 S.W.3d 134, 137 (Tex. 2012).
cited Cited as authority (rule) Sharon P. Jorolan, Logan B. Young, Michelle Pique, Maurice F. Johnson, Patricia Erway, and Lincoln Achilli v. Andy Eads
Tex. App. · 2025 · confidence medium
“Unless standing is conferred by statute, a plaintiff must show that he has suffered a particularized injury distinct from the general public.” Andrade v. Venable, 372 S.W.3d 134, 137 (Tex. 2012).
discussed Cited as authority (rule) International Brotherhood of Electrical Workers, Local 278, Eduardo Rodriguez, Esteban J. Cavazos, Jerry Castillo, David L. Mays Jr., Avery Santos, Andrew Sitterly Jr., Miguel F. Carranco, Michael De La Cruz, Hector Carrillo, David Roberts, Ronnie Flores, Connor Hamilton, Israel Lopez, Chris Hernandez, Christian Sanchez, and Jose A. Martinez v. Corpus Christi Independent School District
Tex. App. · 2024 · confidence medium
But generally, “in order to establish taxpayer standing a plaintiff must plead facts showing that the government is actually spending money on the allegedly illegal activity.” Andrade v. Venable, 372 S.W.3d 134, 138 (Tex. 2012).
discussed Cited as authority (rule) Steven Harvey v. Mark Henry, Galveston County Judge Darrell Apffel, Galveston County Commissioner Precinct 1.
Tex. App. · 2024 · confidence medium
“This is because ‘[g]overnments cannot operate if every citizen who concludes that a public 3 official has abused his discretion is granted the right to come into court and bring such official’s public acts under judicial review.’” Andrade v. Venable, 372 S.W.3d 134, 136 (Tex. 2012) (quoting Bland I.S.D., 34 S.W.3d at 555 ).
discussed Cited as authority (rule) Philip Alan Green and Jonathan Zackhery Wilks v. Texas Comptroller of Public Accounts and Glenn Hegar, in His Official Capacity (2×)
Tex. App. · 2023 · confidence medium
“In general, regardless of the claim asserted, ‘a plaintiff must show that he has suffered a particularized injury distinct from the general public.’” Perez v. Turner, 653 S.W.3d 191 , 199 (Tex. 2022) (quoting Andrade v. Venable, 372 S.W.3d 134, 137 (Tex. 2012)).
cited Cited as authority (rule) John D. Ferrara v. Kim Vickers - Public Official, Texas Commission on Law Enforcement
Tex. App. · 2022 · confidence medium
Comm’n, 411 S.W.3d 161, 174 (Tex.App.—Austin 2013, no pet.)(quoting Andrade v. Venable, 372 S.W.3d 134, 136-37 (Tex. 2012)).
discussed Cited as authority (rule) Elizabeth C. Perez v. Sylvester Turner, Mayor, Karun Sreerama, Director of Public Works and Engineering, and the City of Houston
Tex. · 2022 · confidence medium
In general, regardless of the claim asserted, “a plaintiff must show that he has suffered a particularized injury distinct from the general public.” Andrade v. Venable, 372 S.W.3d 134, 137 (Tex. 2012) (citing Bland Indep.
cited Cited as authority (rule) Jack Pidgeon and Larry Hicks v. Sylvester Turner, in His Official Capacity as Mayor of the City of Houston, and the City of Houston
Tex. App. · 2021 · confidence medium
Andrade v. Venable, 372 S.W.3d 134, 136 (Tex. 2012).
discussed Cited as authority (rule) Best Buy Stores, Inc., Through Its Assignees Paul Denucci, Rockey Piazza, and Linda Piazza v. Glenn Hegar, in His Capacity as Comptroller of Public Accounts of the State of Texas, and Ken Paxton, in His Capacity as Attorney General of the State of Texas
Tex. App. · 2021 · confidence medium
The Scott rule is also similar to “a narrow, judicially-created exception” for taxpayer standing: “a taxpayer has standing to sue to enjoin the illegal expenditure of public funds, and need not demonstrate a particularized injury.” Andrade v. Venable, 372 S.W.3d 134, 137 (Tex. 2012) (per curiam).
discussed Cited as authority (rule) Thomas G. Kilgore v. City of Lakeway, Texas, and Sandy Cox, Ron Massa, Bridge Bertram, Dwight Haley, Steve Smith, and Keith Trecker, in Their Official Capacities (2×) also: Cited "see"
Tex. App. · 2020 · confidence medium
A citizen generally “lacks standing to bring a lawsuit challenging the lawfulness of governmental acts” because “governments cannot operate if every citizen who concludes that a public official has abused his discretion is granted the right to come into court and bring such official’s public acts under judicial review.” Andrade v. Venable, 372 S.W.3d 134, 136 (Tex. 2012).
examined Cited as authority (rule) Elizabeth C. Perez v. Sylvester Turner, Mayor, Karun Sreerama, Director of Public Works and Engineering and the City of Houston (3×) also: Cited "see"
Tex. App. · 2019 · confidence medium
As the Texas Supreme Court stated in both Andrade and 25 Bland Independent School District, “Generally, ‘a citizen lacks standing to bring a lawsuit challenging the lawfulness of governmental acts.’ This is because ‘[g]overnments cannot operate if every citizen who concludes that a public official has abused his discretion is granted the right to come into court and bring such official’s public acts under judicial review.’” Andrade, 372 S.W.3d at 136 (internal citations omitted) (quoting NAACP of Austin, 345 S.W.3d at 6 ); Bland Indep.
discussed Cited as authority (rule) Max Grossman v. Mark Wolfe, Executive Director, Texas Historical Commission (2×) also: Cited "see, e.g."
Tex. App. · 2019 · confidence medium
Constables Ass’n, 546 S.W.3d 661, 666 (Tex. 2018) (noting general rule that unless standing is conferred by statute, plaintiff must demonstrate an interest in conflict distinct from that of general public); Andrade v. Venable, 372 S.W.3d 134, 137 (Tex. 2012) (addressing applicability of judicially created exception to standing for certain taxpayers, but recognizing that standing can be conferred by statute); Williams v. Lara, 52 S.W.3d 171, 178 (Tex. 2001) (same); Bland, 34 S.W.3d at 556 & n. 52 (“Unless standing is conferred by statute, taxpayers must show as a rule that they have suffere…
discussed Cited as authority (rule) the Honorable Mark Henry, County Judge of Galveston County v. the Honorable Lonnie Cox, Judge of the 56th District Court of Galveston County (2×)
Tex. App. · 2015 · confidence medium
Lonnie Cox 1 Contents Authorities………………………………………………………………..………3 Issues Presented…………………………………………………………..………9 Nature of the Case…………………………………………………………..…….9 Trial Court Information……………………………………………………………9 Course of Proceedings…………………………………………………………….9 Trial Court Disposition…………………………………………………………...10 Facts…�…
cited Cited as authority (rule) Texas Department of State Health Services v. Balquinta
Tex. App. · 2014 · confidence medium
Id. at 174-75 (quoting Andrade v. Venable, 372 S.W.3d 134, 136-37 (Tex.2012) (quoting Andrade v. NAACP of Austin, 345 S.W.3d 1, 7 (Tex.2011); Bland, 34 S.W.3d at 555 )). .
cited Cited as authority (rule) George Alejos v. State
Tex. App. · 2014 · confidence medium
Id. at 174-75 (quoting Andrade v. Venable, 372 S.W.3d 134, 136-37 (Tex.2012) (quoting Andrade v. NAACP of Austin, 345 S.W.3d 1, 7 (Tex.2011))); see Bland Indep.
discussed Cited as authority (rule) Lone Star College System and Richard Carpenter v. Immigration Reform Coalition of Texas (IRCOT) (2×) also: Cited "see, e.g."
Tex. App. · 2013 · confidence medium
Andrade v. Venable, 372 S.W.3d 134, 137 (Tex. 2012).
discussed Cited as authority (rule) Lone Star College System and Richard Carpenter v. Immigration Reform Coalition of Texas (IRCOT) (2×) also: Cited "see, e.g."
Tex. App. · 2013 · confidence medium
Andrade v. Venable, 372 S.W.3d 134, 137 (Tex. 2012).
discussed Cited as authority (rule) Stanley Bacon, Jr. v. Texas Historical Commission (2×) also: Cited "see"
Tex. App. · 2013 · confidence medium
They also “reflect in many ways the rule that neither citizens nor taxpayers can appear in court simply to insist that the government and its officials adhere to the requirements of law.” Andrade v. Venable, 372 S.W.3d 134, 136-37 (Tex.2012) (quoting Andrade v. NAACP of Austin, 345 S.W.3d 1, 7 (Tex.2011) (quoting Charles Alan Wright et. al., Federal Practice and Procedure § 3531.10 (3d ed.2008))).
cited Cited "see" Christopher Ramsey, Natasha Randolph, Kyndee Venable, and Aubrey Venable v. Crickett Miller, Pat Deen, George Conley, Craig Peacock, Larry Walden, and Steve Dugan
Tex. App. · 2023 · signal: see · confidence high
See Andrade v. Venable, 372 S.W.3d 134 , 136–37 (Tex. 2012); see also THE FEDERALIST NO. 10 (James Madison) (highlighting various advantages of republican governance over pure democracy).
examined Cited "see" James Robert Jones and Allen Watson v. Sylvester Turner, in His Official Capacity as Mayor of the City of Houston (3×)
Tex. · 2022 · signal: see · confidence high
See Andrade v. Venable, 372 S.W.3d 134, 138 (Tex. 2012) (holding that the illegal expenditure must be significant, not de minimis).
cited Cited "see" Mark Young v. Bella Palma, LLC
Tex. App. · 2022 · signal: see · confidence high
See Andrade v. Venable, 372 S.W.3d 134, 137 (Tex. 2012) (per curiam); Williams v. Lara, 52 S.W.3d 171, 178 (Tex. 2001); Hunt v. Bass, 664 S.W.2d 323, 324 (Tex. 1984).
discussed Cited "see" Sylvester Turner v. James Robert Jones
Tex. App. · 2020 · signal: see · confidence high
See Andrade v. Venable, 372 S.W.3d 134, 138 (Tex. 2012) (per curiam) (“In order to establish taxpayer standing a plaintiff must plead facts showing that the government is actually spending money on the allegedly illegal activity—not on a related legal activity.”).
discussed Cited "see" Robert K. Nelson, Mayor Julie Estlinbaum, Councilwoman, Position 1, Bill Cornman, Councilman, Position 2, and the City of Bay City, Texas v. Robert Neal Head (2×)
Tex. App. · 2019 · signal: see · confidence high
See Andrade v. Venable, 372 S.W.3d 134, 137 (Tex. 2012) (per curiam) ([U]nder Texas law, a narrow, judicially-created exception exists: a taxpayer has standing to enjoin the illegal expenditure of public funds and need not demonstrate a particularized injury.” (citing Williams v. Lara, 52 S.W.3d 171, 179 (Tex. 2001))).
cited Cited "see" Primestar Construction, Inc. v. City of Dallas, Texas
Tex. · 2018 · signal: see · confidence high
See Andrade v. Venable, 372 S.W.3d 134, 137 (Tex. 2012); Everett v. TK-Taito, L.L.C., 178 S.W.3d 844, 850 (Tex. App.--Fort Worth 2005, no pet.).
discussed Cited "see" Turner v. Robinson (2×) also: Cited "see, e.g."
Tex. App. · 2017 · signal: see · confidence high
See Venable, 372 S.W.3d at 137 ; Williams, 52 S.W.3d at 179; Calvert v. Hull, 475 S.W.2d 907, 908 (Tex. 1972); Osborne, 177 S.W.2d at 200 ; Hoffman v, Davis, 128 Tex, 503, 100 S.W.2d 94, 95 (1937) ("When a taxpayer brings an action to restrain the illegal expenditure ... of tax money he sues for himself, and it is held that his interest in the subject-matter is sufficient to support the action’’); Terrell v. Middleton, 187 S.W. 367, 369 (Tex. Civ,- App.—San Antonio 1916), writ ref'd, 108 Tex; 14, 191 S.W. 1138 (1917) (per curiam); City of Austin v. McCall, 95 Tex. 565 , 68 S.W. .791, 794…
cited Cited "see" Jody Weiderman v. the City of Arlington, Texas And Jeff Williams, Mayor in His Official Capacity
Tex. App. · 2015 · signal: see · confidence high
See Andrade v. Venable, 372 S.W.3d 134 , 137–39 (Tex. 2012).
cited Cited "see" Jody Weiderman v. the City of Arlington, Texas And Jeff Williams, Mayor in His Official Capacity
Tex. App. · 2015 · signal: see · confidence high
See Andrade v. Venable, 372 S.W.3d 134, 137-39 (Tex.2012).
cited Cited "see" Zaan, LLC v. Barry Sangani, Sangini Properties, LTD, Kathy Webster
Tex. App. · 2015 · signal: see · confidence high
See Andrade v. Venable, 372 S.W.3d 134 , 138−39 (Tex. 2012); Mazon Assoc., Inc. v. Comerica Bank, 195 S.W.3d 800, 803 (Tex. App.—Dallas 2006, no pet.).
cited Cited "see" Salazar v. Wilson
Tex. App. · 2014 · signal: see · confidence high
See Andrade v. Venable, 372 S.W.3d 134, 138 (Tex.2012); Miranda, 133 S.W.3d at 226 .
examined Cited "see" City of New Braunfels, Texas v. Stop the Ordinances Please W. W. GAF, Inc. D/B/A Rockin R River Rides Texas Tubes Tourist Associated Businesses of Comal County Union River LLC D/B/A Landa River Trips Chuck's Tubes Waterpark Management, Inc. Tri-City Distributors, LP (4×)
Tex. App. · 2013 · signal: see · confidence high
See Andrade v. Venable, 372 S.W.3d 134, 138 (Tex. 2012) (per curiam); Williams v. Lara, 52 S.W.2d 171, 179-83 (Tex. 2001); Bland Indep.
discussed Cited "see, e.g." Texas Department of State Health Services And Kyle Janek, in His Official Capacity as Executive Commissioner of the Texas Health and Human Services Commission v. Marcela Balquinta Planned Parenthood of Greater Texas Family Planning and Preventative Health Services, Inc. Planned Parenthood Association of Hidalgo County Texas, Inc. Planned Parenthood Association of Lubbock, Inc.
Tex. App. · 2014 · signal: see also · confidence low
Sys. v. Koseoglu, 233 S.W.3d 835, 844 (Tex. 2007) (quoting Kentucky v. Graham, 473 U.S. 159, 165 (1985))). 51 See Texas Ass’n of Bus., 852 S.W.2d at 443–45; Bacon v. Texas Historical Comm’n, 411 S.W.3d 161, 174 (Tex. App.—Austin 2013, no pet.). 16 occasions for judicial action’ and thus maintain the proper separation of governmental powers.”52 “Further, with regard to complaints about governmental action in particular, standing doctrines serve to prevent judicial incursions into abstract or generalized public policy disputes that are properly resolved in the other branches.”53 …
Retrieving the full opinion text from the archive…
Honorable Hope ANDRADE, Petitioner,
v.
Don VENABLE, Respondent
11-0008.
Texas Supreme Court.
May 18, 2012.
372 S.W.3d 134
Michele Tapia, Dallas County District Attorney’s Office, David L. Finney, Dallas County Criminal District Attorney, Houston, for Bruce Sherbet., Don Venable, Coppell TX, for Don Vena-ble., Kathlyn C. Wilson, Assistant Attorney General, Robert B. O’Keefe, General Litigation Division, David C. Mattax, Director of Defense Litigation, William J. “Bill” Cobb III, Office of the Attorney General, Daniel T. Hodge, First Asst. Attorney General, Attorney General Greg W. Abbott, Attorney General of Texas, Austin TX, for Hope Andrade.
Per Curiam.
Cited by 38 opinions  |  Published
PER CURIAM.

Don Venable seeks to enjoin Dallas County from identifying candidates’ political party affiliations and providing a “straight-party” option on general election ballots. We must decide whether Venable has standing to pursue these claims. Because Venable has no interest distinct from that of the general public and has not established taxpayer standing under Williams v. Lara, 52 S.W.3d 171,179 (Tex. 2001), we reverse in part the court of appeals’ judgment and render judgment dismissing Venable’s claims against Secretary of State Hope Andrade.

The Texas Election Code requires that election ballots identify each candidate’s party affiliation. Tex. Elec.Code § 52.065(c). It also mandates that ballots contain a straight-party voting option. Id. § 52.071(b). Venable believes that these requirements violate Article VI, Section 4 of the Texas Constitution, because they neither punish fraud nor preserve ballot box purity. [1] According to Venable, these statutory requirements merely benefit political parties, which is not a legitimate governmental function. Venable also argues that these same provisions violate Article III, Section 52(a) because public money is used to advance the interests of discrete political parties. [2]

[*136] Venable sued Dallas County Elections Administrator Bruce Sherbet to permanently enjoin him from: (1) using county funds to identify candidates’ political party affiliations and (2) providing a straight-party option on any general election ballot. Venable later added Secretary of State Hope Andrade. Sherbet and Andrade filed jurisdictional pleas. Sherbet challenged the existence of facts to support Venable’s claim of taxpayer standing. An-drade argued that, even accepting all of his allegations as true, Venable did not allege facts sufficient to affirmatively demonstrate jurisdiction.

Venable then amended his petition, alleging the following jurisdictional facts: (1) he is a property taxpayer in Dallas County, (2) the expenses incurred in the conduct of a" general election are solely Dallas County’s financial responsibility, (3) Sherbet, a salaried county employee, is the Dallas County Elections Administrator, (4) preparation of the official ballots in Dallas County for general elections is one of Sherbet’s ministerial responsibilities, (5) in addition to the required actions needed to prepare a ballot, Sherbet is required to satisfy the additional ballot construction rules as required by the Texas Election Code relating to the printing of political party names and straight-party tickets, and (6) the Dallas County Elections Department is fully funded by the Dallas County General Fund for fiscal year 2010. Venable incorporated by reference a purported copy of Dallas County’s adopted budget for fiscal year 2010.

The trial court granted both pleas and Sherbet’s accompanying motion to dismiss. Venable appealed. The court of appeals held that Venable’s amended petition pleaded sufficient facts to affirmatively demonstrate taxpayer standing. 365 S.W.3d 359, 367. Although the court acknowledged that Venable did not explicitly state that Dallas County was actually expending public funds on the allegedly illegal activity, the court construed his pleadings to say that Dallas County actually expends public funds when it includes the political party identification of the candidates on the ballot and offers a straight-party voting option. The court also held that Sherbet failed to present evidence to support his challenge to the existence of jurisdictional facts. The court reversed the trial court’s judgment and remanded the case to the trial court. Id. at 367.

Only Andrade petitioned this Court for review, arguing that Venable lacks taxpayer standing because he failed to plead facts showing that the government actually spends money on the activity he challenges.

Generally, “a citizen lacks standing to bring a lawsuit challenging the lawfulness of governmental acts.” Andrade v. NAACP of Austin, 345 S.W.3d 1, 6 (Tex.2011). This is because “[gjovernments cannot operate if every citizen who concludes that a public official has abused his discretion is granted the right to come into court and bring such official’s public acts under judicial review.” Bland Indep. Sch. Dist. v. Blue, 34 S.W.3d 547, 555 (Tex.2000) (alteration in original) (citing Osborne v. Keith, 142 Tex. 262, 177 S.W.2d 198, 200 (1944)). “Thus, ‘[standing doc[*137] trines reflect in many ways the rule that neither citizens nor taxpayers can appear in court simply to insist that the government and its officials adhere to the requirements of law.’ ” Andrade, 345 S.W.3d at 7 (quoting ChaRles Alan WRIGht ET AL., FEDERAL PRACTICE AND PROCEDURE § 3531.10 (3d ed.2008)).

Unless standing is conferred by statute, a plaintiff must show that he has suffered a particularized injury distinct from the general public. Bland Indep. Sch. Dist., 34 S.W.3d at 555-56. This bar against generalized grievances applies to suits brought by citizens as voters. See Brown v. Todd, 53 S.W.3d 297, 302 (Tex. 2001) (“No Texas court has ever recognized that a plaintiffs status as a voter, without more, confers standing to challenge the lawfulness of governmental acts.”). However, under Texas law, a narrow, judicially-created exception exists: a taxpayer has standing to sue to enjoin the illegal expenditure of public funds, and need not demonstrate a particularized injury. Williams, 52 S.W.3d at 179; Bland Indep. Sch. Dist., 34 S.W.3d at 556; Osborne, 177 S.W.2d at 200; Hoffman v. Davis, 128 Tex. 503, 100 S.W.2d 94, 95 (1937); City of Austin v. McCall, 95 Tex. 565, 68 S.W. 791, 794 (1902). “Implicit in this rule are two requirements: (1) that the plaintiff is a taxpayer; and (2) that public funds are expended on the allegedly illegal activity.” Williams, 52 S.W.3d at 179.

In Williams, we examined taxpayer standing in a challenge to a religious education program at a county jail. Id. at 177-79. The plaintiff argued that because he paid taxes, and public funds helped administer the program at the corrections center, he had standing to enjoin its allegedly illegal operation. Id. at 179. The money was used to feed, clothe, and house the prisoners. Id. Two county-paid employees spent a portion of their time supervising the program. Id. This was enough, the taxpayer alleged, to conclude that the county was spending public money on this allegedly illegal activity. Id. We considered for the first time what constitutes “expending funds” in a taxpayer standing case. Id. at 181. To help answer this question, we looked to federal jurisprudence regarding municipal taxpayer standing. Id.

We noted that to be entitled to federal municipal taxpayer standing, “a litigant must prove that the government is actually expending money on the activity that the taxpayer challenges; merely demonstrating that tax dollars are spent on something related to the allegedly illegal conduct is not enough.” Id. We cited several cases in which taxpayers lacked standing, including cases where the funds would have been spent regardless of the challenged activity. [3] We agreed with the county that be[*138] cause the money used to feed, clothe, and house the inmates would be spent regardless of the religious program’s existence, those expenditures alone were insufficient to establish that the government actually expended money on the challenged activity. Id. at 182.

We determined that other aspects of the program’s operation involved the use of public funds, however. Id. We held that because county-paid employees spent a “significant amount of the County’s time” operating the program, including shaping and promoting its religious curriculum, county funds were expended in operating the program. Id. at 183. We based our conclusion not just on the fact that salaried county employees worked on the program, but also because the record established that the employees’ involvement was “anything but incidental.” Id. There, the employees “personally and directly operated and managed” the challenged program “while on the county payroll.” Id.

Thus, under Williams, in order to establish taxpayer standing a plaintiff must plead facts showing that the government is actually spending money on the allegedly illegal activity — not on a related legal activity. See id. at 182-83. This must be a measurable, added expenditure — not one that would have been made in spite of the allegedly illegal activity. See id. at 182. The plaintiff must be able to allege that the challenged activity “is supported by any separate tax or paid for from any particular appropriation or that it adds any sum whatever to the cost of conducting the [challenged activity].” Doremus v. Board of Educ. Of the Borough of Hawthorne, 342 U.S. 429, 433, 72 S.Ct. 394, 96 L.Ed. 475 (1952). Moreover, the expenditure cannot be de minimis — it must be significant. Cf. id. at 434 (explaining the Court’s finding of a justiciable controversy in a case that “showed a measurable appropriation or disbursement of school-district funds occasioned solely by the activities complained of’); Williams, 52 S.W.3d at 183 (noting that county-paid employees “spent a significant amount” of time operating the challenged program). Unless a plaintiff can meet these requirements, there has not been a pecuniary injury to the taxpayers generally and the taxpayer’s interest is not direct enough for his suit to proceed.

The parties do not dispute that Venable is a Dallas County resident and taxpayer. We must decide whether Venable has alleged facts showing that Dallas County expends public funds when it includes candidates’ party affiliations and the straight-party option on the ballot.

Venable contends his “sole burden concerning the issue of public funding was to allege the use of public money in the challenged conduct.” But Williams makes clear that a taxpayer must plead facts showing that the government is actually spending money specifically on the challenged activity. Williams, 52 S.W.3d at 178-81. A taxpayer plaintiff, like any other plaintiff, carries the initial burden of alleging facts that affirmatively demonstrate the trial court’s jurisdiction. See Tex. Dep’t of Parks & Wildlife v. Miranda, 133 S.W.3d 217, 226 (Tex.2004).

Venable’s petition incorporated by reference Dallas County’s adopted budget for fiscal year 2010, which reflected general election expenses. He argues that the budget shows that public funds were being spent on the challenged activities. But simply including Dallas County’s budget does not show that a measurable amount of public funds are being expended solely on the allegedly illegal activity. As the court of appeals noted, Venable’s pleadings did “not explicitly state that Dallas County is actually expending public funds on the[*139] allegedly illegal activity.” 365 S.W.3d at 359. But because he “attempt[ed] to link the expenditure of public funds to the allegedly illegal activity,” the court of appeals generously construed the pleadings “to claim that Dallas County is actually expending public funds ... when it includes the political party identification of the candidates on the ballot and offers a straight-party voting option.” Id. at 367. [4]

We disagree. Venable has, at most, alleged that Dallas County spends money on elections — not that preparing and printing ballots with candidates’ political affiliations and a straight-party voting option costs any more than ballots without them. As we stated in Williams, merely demonstrating that tax dollars are spent on something related to the allegedly illegal conduct is not enough. Williams, 52 S.W.3d at 181. Nor is it sufficient for the taxpayer plaintiff to point to costs that would have been incurred regardless of the allegedly illegal activity. Id. at 181-82. A taxpayer does not have an interest direct enough to warrant standing unless the activity challenged involves an expenditure of public funds that would not otherwise be made.

Venable argues that he has complied with Williams because he has alleged that county employees were involved in the preparation of the ballots, which were required by the Elections Code to identify candidates’ political parties and to offer a straight-party voting option. But as one of the eases we cited in Williams explained, “[n]early all governmental activities are conducted or overseen by employees whose salaries are funded by tax dollars. To confer taxpayer standing on such a basis would allow any municipal taxpayer to challenge virtually any governmental action at any time.” Altman v. Bedford Cent. Sch. Dist., 245 F.3d 49, 74 (2d Cir. 2001). A government employee’s time spent on the allegedly illegal activity must be significant to serve as a basis for taxpayer standing. Williams, 52 S.W.3d at 183.

Here, Dallas County would incur labor costs for preparing the ballots or programming the computers for electronic voting, regardless of the inclusion of candidates’ party affiliations and a straight-party voting option on the general election ballot, and Venable does not allege that there is any incremental increase in cost related to the statutory requirements. Even if Vena-ble were able to identify the additional labor costs the county incurred for time county-paid employees spend on the activity he challenges, Williams requires that such time be “significant” — something Venable has neither pleaded nor proved. Id.

Venable has not pleaded facts showing that measurable and significant public funds were being spent on the activity he challenges, and thus, has failed to affirmatively demonstrate taxpayer standing. Because Venable has no interest distinct from that of the public generally, and his claims fall outside the narrow taxpayer exception to the bar against generalized grievances, he lacks the requisite and particularized stake to warrant standing. Accordingly, we grant the petition for review, and without hearing oral argument, we reverse in part the court of appeals’ judgment and render judgment dismissing Venable’s[*140] claims against Andrade. Tex.R.App. P. 59.1, 60.2(c).

1

. Article VI, Section 4 of the Texas Constitution provides:

In all elections by the people, the vote shall be by ballot, and the Legislature shall provide for the numbering of tickets and make such other regulations as may be necessary , to detect and punish fraud and preserve the purity of the ballot box; and the Legislature shall provide by law for the registration of all voters.

Tex Const, art. VI, § 4.

2

. Article III, Section 52(a) provides:

Except as otherwise provided by this section, the Legislature shall have no power to authorize any county, city, town or other[*136] political corporation or subdivision of the State to lend its credit or to grant public money or thing of value in aid of, or to any individual, association or corporation whatsoever, or to become a stockholder in such corporation, association or company. However, this section does not prohibit the use of public funds or credit for the payment of premiums on nonassessable property and casualty, life, health, or accident insurance policies and annuity contracts issued by a mutual insurance company authorized to do business in this-State.

Tex. Const, art. Ill, § 52(a).

3

. See, e.g., Doe v. Madison Sch. Dist. No. 321, ill F.3d 789, 794 (9th Cir.1999) ("Doe identifies no tax dollars that defendants spent solely on the graduation prayer, which is the only activity that she challenges. In fact, Doe acknowledges affirmatively that '[t]he prayers ... cost the state no additional expense.’ Doe instead alleges that defendants spent tax dollars on renting a hall, printing graduation programs, buying decorations, and hiring security guards. But those are ordinary costs of graduation that the school would pay whether or not the ceremony included a prayer. Therefore, those expenditures cannot establish taxpayer standing.”) (alterations in original); Gonzales v. N. Twp. of Lake Cnty., Ind., 4 F.3d 1412, 1416 (7th Cir.1993) ("In this case, however, the plaintiffs’ claim is undercut by their inability to show that tax revenue is spent for the crucifix_ [Although Township funds are spent maintaining the Park areas surrounding the crucifix, this cost would be incurred with or without the presence of the crucifix. Without evidence of expenditure of tax revenues, the plaintiffs cannot claim standing by virtue of their taxpayer status.”).

4

. We do not agree with the court of appeals that the record does not show that the trial court gave Venable the opportunity to amend his pleadings. 365 S.W.3d at 359. Venable had an opportunity to amend his petition after Andrade and Sherbet filed their jurisdictional pleas, and in fact, he did so. Even construing his petition liberally and looking to his intent, he failed to affirmatively demonstrate that he has taxpayer standing because he has not shown that the county actually expends funds on the activity he challenges.