Cause Number
‘THE STATE OF TEXAS x IN THE (MUNICIPAL) JUSTICE)
x (COUNTY)(DISTRICT) COURT
COUNTY OF x COUNTY TEXAS
AFFIDAVIT FOR WARRANT OF ARREST AND DETENTION
Before ME, the undersigned authority, on this day, the undersigned Affiant, wo after being duly sworn by me, on oath,
makes the following statement:
My name is Jeffrey C. Lyde, and | am the duly elected Sheriff of Clay County Texas according to the laws of the State of
‘Texas and | have good reason to believe and do in fact believe that on or before the making and filing of this affidavit, that
James Michael Campbell, W/M, 008 has committed multiple offenses against the Open Meetings Act to wit:
551.143 Local Government Code, Prohibited Series of Communications
On Wednesday, August 17, 2022, | was present and have personal knowledge that in an
executive session of the Clay County Hospital Board of Managers, Campbell outlined how three of the
commissioners would vote concerning an Item on the agenda for Monday, August 22, 2022. Since the agenda
for the Commissioners Court would not come out until Friday, August 19 and the vote would not happen until
the 22", there is no way for Campbell to know how the others would vote unless he had contacted those three
commissioners and discussed the matter outside of an open meeting. This is the definition of a “walking
quorum” and a violation of 551.143 LGC, a misdemeanor punishable by (1) a fine of not less than $100 or more
than $500; (2) confinement in the county jail for not less than one month or more than six months; or (3) both
the fine and confinement.
551.146 Local Government Code, Disclosure of Certified Agenda or Recording of Closed
Meeting.
On Wednesday, August 17, 2022, the above information was relayed to me by Dr, Andy Wilson, a credible
person, who was told this information by James Michael Campbell. As this information was only available to
Persons who were in the closed session, Dr. Wilson could not have been in possession of this knowledge without
someone who was in attendance telling him. Dr. Wilson informed me of the breech immediately after
Campbell's disclosure. On Sunday, August 21, 2022, at a dinner with Dr. Wilson, Lisa Swenson, James Michael
Campbell and myself, Campbell reiterated the outcome of the vote that would happen on the following day and
this time disclosed the information to Lisa Swenson, CEO of Clay County Memorial Hospital. This offense is a
Class B Misdemeanor.
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551.145 Local Government Code, Closed Meeting Without Certified Agenda or Recording.
(On Monday, August 22, 2022, I went to the County Clerk’s Office and spoke to County Clerk Sasha Kelton concerning the
official records of closed session meetings of the Clay County Commissioner's Court. Mrs. Kelton informed me that
although she isthe official repository for the meeting minutes, she does not have, nor is she aware of any records of closed
meetings of the Court, On that same day and immediately after speaking to Mrs. Kelton, | spoke to the County Judge’s
Assistant Becky Mataska and asked her the same questions | had asked of Mrs. Kelton. Mrs. Mataska responded in the
same manner as Mrs. Kelton and stated that she also did not keep the records and was not aware of any records being
kept. Later that same day, | spoke to Precinct 3 Commissioner Retta Collins who, did not discuss anything of the substance
of the conversations had in closed meetings, did confirm that no official records are kept of the closed meetings. | did
make her aware that they were required to be kept and of the penalties for not doing so. She assured me that she would
make sure a certified agenda would be made at future meetings. This offense is a Class C Misdemeanor.
WHEREFORE, Affiant requests that an arrest warrant be issued for the above accused individual, James Michael Campbell,
onal three offenses.
AGAINST THE PEACE AND DIGNITY OF THE STATE
AFFIANT, Jeffrey Lyde
Clay County Sheriff
ON THIS THE DAY OF 2022, | HEREBY ACKNOWLEDGE | HAVE
EXAMINED THE FOREGOING AFFIDAVIT AND HAVE DETERMINED THAT PROBABLE CAUSE EXISTS FOR THE ISSUANCE OF
WARRANTS FOR THE ARREST OF JAMES MICHAEL CAMPBELL AS DESCRIBED IN THE FOREGOING AFFIDAVIT.
Magistrate in and for the State of Texas
THE STATE OF TEXAS Warrant #:
VS.
NAME: James Michael Campbell Clay County Sheriff's Office
Aliases: Mike Campbell OFFENSE #; TBD
OFFENSE DATE: Multiple
ADDRESS:
city: PEACE OFFICER: J.C. Lyde #1128
THE STATE OF TEXAS
TO ANY PEACE OFFICER OF THE STATE OF TEXAS, GREETINGS:
You are hereby commanded to arrest:
mes Michael CampbellW,
If to be found in your County and bring him/her before me, at my office, or to the Sheriff of the county where
found, then and there to answer the State of Texas for an offense against the laws of said State, to-wit:
Multiple offenses against the Open Meetings Act ~ See Affidavit Attached
of which offenses he is accused by the written complaint, under oath, of Sheriff Jeffrey C. Lyde filed before
me.
HEREIN FAIL NOT but of this writ make due return, showing how you have executed the same.
WITNESS my official signature, this day of September A.D. 2022.
BOND $:
Magistrate
State of Texas
PEACE OFFICER’S RETURN:
Came at hand the day of AD, at o'clock _M. and executed on
the day of AD, at o'clock _M., by arresting the within named
in County, Texas, and taking his bond,
placing him in jail at
BY.
Peace Officer
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