Article VII, Section 2 of the Texas Constitution (discussion page)
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Submerged lands, as lands under navigable waters, were held in trust for the people by the state, and could be sold only by the legislature. Lorino v. Crawford Packing Co., 175 S.W.2d 410, 413 (Tex. 1943); City of Galveston v. Mann; 143 S.W.2d 1028, 1033-34 (Tex. 1940); State v. Bradford, 50 S.W.2d 1065,1069-70 (Tex. 1932)
Consistent with article VII, section 4, land belonging to the Permanent School Fund “must be sold and may be disposed of only by sale.” Weatherly v. Jackson, 71 S.W.2d 259,266 (Tex. 1934). “Article [VII], [slection 4 . . . says that Public School Lands ‘shall be sold.’ There must be a sale; otherwise, one collides with the constitutional prohibition of gifts of public lands.”
Cobra Oil & Gas Corp. v. Sadler, 447 S.W.2d 887,898 (Tex. 1969). The state may not dispose of Permanent School Fund land by gift. See Wheeler v. Stanolind Oil h Gas Co., 252 S.W.2d 149, 152 (Tex. 1952)
Empire Gas & Fuel Co. v. State, 47 S.W.2d 265, 275 (Tex. 1932)