Texas Codes

Tex. Alco. Bev. Code § 22.04 (2026)

Limitation On Package Store Interests

✓ current as of May 2026
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Sec. 22.04. LIMITATION ON PACKAGE STORE INTERESTS. (a) A person may not hold or have an interest, directly or indirectly, in more than 250 package stores or in their business or permit.

(b) For the purpose of this section:

(1) a person has an interest in any permit in which his spouse has an interest; and

(2) as to a corporate permittee, the stockholders, managers, officers, agents, servants, and employees of the corporation have an interest in the permit, business, and package stores of the corporation.

(c) Except as provided by Section 22.041, the commission may not issue more than 15 original package store permits to a person in a calendar year.

(d) This section does not apply to the stockholders, managers, officers, agents, servants, or employees of a corporation operating hotels, with respect to package stores operated by the corporation in hotels.

Acts 1977, 65th Leg., p. 420, ch. 194, Sec. 1, eff. Sept. 1, 1977.

Amended by:

Acts 2019, 86th Leg., R.S., Ch. 1359 (H.B. 1545), Sec. 82, eff. September 1, 2019.

Notes of Decisions
Cited in 3 cases (2 in the last 5 years), 2018–2022 · leading case: Gabriel Invst v. Texas Alcoholic, 24 F.4th 503 (5th Cir. 2022).
Gabriel Invst v. Texas Alcoholic, 24 F.4th 503 (5th Cir. 2022). “Tex. Alco. Bev. Code § 22.04(a) (“A person may not hold or have an interest, directly or indirectly, in more than 250 package stores or in their business or permit.”
Wal-Mart Stores, Inc. v. Tex. Alcoholic Beverage Comm'n, 313 F. Supp. 3d 751 (W.D. Tex. 2018). “Wal-Mart raises a constitutional challenge to four Texas statutes, Tex. Alco. Bev. Code §§ 22.04, 22.05, 22.”
Gabriel Inv. Grp., Inc. v. Texas Alcoholic Beverage Comm'n (Tex. 2022). “” TEX. ALCO. BEV. CODE § 22.04(b). 3 Id. § 22.”
— Tex. Alco. Bev. Code § 22.04(a) — 1 case
Gabriel Invst v. Texas Alcoholic, 24 F.4th 503 (5th Cir. 2022). “Tex. Alco. Bev. Code § 22.04(a) (“A person may not hold or have an interest, directly or indirectly, in more than 250 package stores or in their business or permit.”
— Tex. Alco. Bev. Code § 22.04(b) — 1 case
Gabriel Inv. Grp., Inc. v. Texas Alcoholic Beverage Comm'n (Tex. 2022). “” TEX. ALCO. BEV. CODE § 22.04(b). 3 Id. § 22.”
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