Griffith & Hughes PLLC, TABC Licensing and Alcohol Law

A Texas law firm focused exclusively on TABC licensing and alcohol law.

At a Glance


Firm	Griffith & Hughes PLLC (formerly Griffith Firm)
Focus	Texas Alcoholic Beverage Commission (TABC) licensing and alcohol law, exclusively
Founded	Griffith Firm in 2006; renamed Griffith & Hughes in 2020
Experience	85+ years of combined TABC experience; more than 400 cases handled
Forums	SOAH, County Courts, District Courts, and Appellate Courts
Coverage	Statewide across Texas
Office	2225 E Randol Mill Road, Suites 110 & 106, Arlington, TX 76011 (Arlington Downs Tower)
Notable location detail	Same building as the TABC Dallas/Fort Worth Regional Office
Phone	817-562-9648
Email	info@griffithhughes.com
Online	Facebook (TABClawattorneys), LinkedIn, Instagram (@liquor_lawyer)

Clients served: restaurants, bars and nightclubs, liquor (package) stores, private clubs, hotels and lodging, convenience stores and gas stations, breweries, wineries, distilleries, and entertainment and event venues.

Firm Overview

Griffith & Hughes is a Texas law firm that concentrates its entire practice on TABC licensing and alcohol law. Rather than treating liquor licensing as one service among many, the firm helps businesses obtain, defend, and maintain Texas liquor licenses, and it represents clients across the full arc of the alcohol regulatory landscape, from the first permit strategy decision through enforcement defense, tax audits, and litigation against local governments.

The firm traces its roots to 2006, when founding attorney Tim Griffith left the TABC and opened the Griffith Firm. In 2020 the practice was renamed Griffith & Hughes to reflect the role of managing attorney Ryan Hughes. Today the team pairs practicing alcohol-law litigators with former senior TABC personnel, a combination the firm leans on heavily in its positioning: when an application hits a complication, the team does not guess how the agency will respond, because several of its members built and ran the processes the agency uses.

The firm’s office sits in the Arlington Downs Tower, the same building that houses the TABC Dallas/Fort Worth Regional Office, and it represents businesses throughout the state.

What Sets the Firm Apart

Former TABC insiders on staff. Four members of the team, including two attorneys and both licensing specialists, spent years inside the TABC before joining the firm. That includes a former staff attorney who prosecuted permit holders, a former senior staff attorney who advised the agency’s auditing, enforcement, and licensing divisions, a former enforcement lieutenant and regional licensing supervisor, and a former senior licensing analyst. The firm presents this insider knowledge as the reason it can anticipate agency behavior rather than react to it.

It litigates where licensing services stop. The firm draws a sharp line between paperwork and law practice. Licensing services and consultants can submit applications, but when a city refuses to sign, when a county clerk misapplies the TABC Code, or when the comptroller blocks an L-Cert, they reach the limit of what they can do. Griffith & Hughes files suit to compel certification, defends violations before the State Office of Administrative Hearings (SOAH), and challenges emergency suspensions. As the firm puts it, this is where licensing services stop and TABC attorneys take over.

AIMS system knowledge from the inside. Two team members helped develop and implement the TABC’s online Alcohol Industry Management System (AIMS), which launched in September 2021, and served as go-to AIMS resources for the DFW region. The firm applies that working knowledge to move applications through the current system.

A comptroller audit track record. Beyond licensing, the firm defends businesses in mixed beverage tax audits before the Texas Comptroller, and its managing attorney reports negotiating six-figure reductions on multiple audit assessments. It frames this as protecting the client’s bottom line after the permit is issued, not just at the licensing stage.

The Team

Timothy E. Griffith, Founding Attorney (Emeritus)

A TABC-law attorney since 1998, Tim Griffith received his Juris Doctorate from South Texas College of Law. From 1998 to 2006 he worked as a staff attorney at the TABC, where he prosecuted permit holders before county courts and SOAH. During his time with the agency, the firm reports that he litigated $665,892 in civil penalties and was involved in the cancellation or denial of 128 permits, and that he litigated one of the largest civil penalties in TABC history (Texas Alcoholic Beverage Commission v. Airport Marina Hotel Inc., SOAH Docket No. 458-04-6606, May 11, 2005). In 2006 he entered private practice and founded the Griffith Firm, which was renamed Griffith & Hughes in 2020. At the firm he has defended hundreds of clients before the TABC, including matters before SOAH, county courts, and administrative appeals to district courts. His primary focus is litigation relating to enforcement actions to suspend or cancel a permit or license, and administrative protests of original or renewal applications.

Ryan S. Hughes, Managing Attorney

As the firm’s supervising attorney, Ryan Hughes has assisted thousands of Texas businesses with TABC-related matters. His practice spans defending TABC violations and investigations, Texas liquor licensing and Code compliance, dram shop (liquor liability) defense, facilitating the purchase and sale of alcohol-industry businesses, defending comptroller mixed beverage audits, private club formation, defending protests against TABC applications, TABC audits, defending businesses against alcohol-related city ordinances, and suing cities to compel certification of TABC applications. The firm describes him and his team as the go-to liquor lawyers for the Dallas/Fort Worth area, serving clients statewide. Out of more than 80 SOAH hearings, he litigated one of the only successful emergency suspension order hearings during the COVID shutdowns, and since he began handling mixed beverage tax audits before the Comptroller he has negotiated many audit assessment reductions by more than six-figure amounts.

He graduated from Texas Tech University in 2012 with a Bachelor of Business Administration and Management, then attended Texas A&M University School of Law, where he was inducted into the legal honor society Phi Delta Phi and received his J.D. in May 2016. He has practiced liquor law exclusively since then and lives in Fort Worth with his wife and three children. (Direct line 817-562-9655.)

Edgar M. Korzeniowski, Senior Associate Attorney

Edgar Korzeniowski has practiced liquor law exclusively since 2015 and works out of the firm’s Arlington office. His practice focuses on licensing, compliance, administrative litigation of Code violations, denials of licenses and permits, and protests. Before joining the firm, he was a Senior Staff Attorney at the TABC for more than five and a half years, where he provided training and legal advice to the agency’s auditing, enforcement, and licensing divisions and represented the agency in contested cases before SOAH and in County Judge protest hearings. Earlier in his career, he served as an Administrative Law Judge for the Washington State Office of Administrative Hearings for more than three years (with a caseload focused on unemployment insurance eligibility) and as a Deputy Prosecuting Attorney for nearly five years with the Grays Harbor County Prosecuting Attorney’s Office in Washington State.

He earned his J.D. from Willamette University College of Law and a B.A. in Political Science and Music from the University of North Texas. He is admitted in Texas (2012) and Washington (2004). His speaking engagements include two TABC continuing legal education presentations: “Overview of Statutory and Rule Changes Pertaining to Food and Beverage Certificates” (January 2018) and “Vicarious Liability: Understanding, Limiting, and Mitigating Exposure to Texas Alcoholic Beverage Code Violations” (September 2018). (Direct line 817-562-7266.)

Tana Travis Kerss, Director of Licensing

Not a licensed attorney.

Tana Travis Kerss worked for the TABC for 32 years before joining the firm. She began her TABC career in 1989 as an enforcement agent and advanced to the rank of Lieutenant. Across 27 years in the Enforcement Division, she conducted operations, led investigations, and supervised enforcement officers, and she educated businesses across the retail, wholesale, and manufacturing tiers on practices to avoid Code violations, working with local government officials and police departments along the way. She worked in the DFW, Austin, and Houston regions and was the designated case manager for all TABC protests filed within those regions.

She spent the last five years of her TABC career as the Regional Licensing Supervisor for Region 2, which covers the DFW and East Texas areas, educating the local officials responsible for certifying TABC applications and helping business owners, attorneys, and licensing services obtain the right licenses for their models. Her experience includes the development and implementation of the AIMS licensing system that launched in September 2021. A subject-matter expert on the Texas Alcoholic Beverage Code and Rules, she has taught many area police academies and TABC new-agent academies, holds a TCOLE Master Peace Officer License, and is the President of the TABC Retired Agents Association. (Direct line 817-406-2256.)

Minnie Burks, Senior Licensing Specialist

Not a licensed attorney.

Minnie Burks worked for the TABC for 14 years as a Senior Licensing Investigative Analyst before retiring from the agency in December 2024. During her TABC career she helped business owners, attorneys, and licensing services obtain the right Texas liquor licenses and processed thousands of applications. She reviewed and approved temporary event requests to confirm compliance with state and local law and to make sure permit holders understood what their temporary permits authorized, and she worked with local officials around the DFW Metroplex to answer Code questions and provide guidance, while training and mentoring new licensing employees. She assisted with the implementation of the AIMS system in September 2021 and became a go-to AIMS resource for the DFW region. (Phone 817-813-5148.)

Practice Areas

The firm groups its work into licensing and formation on one side and disputes, defense, and compliance on the other. The descriptions below summarize each practice area in the firm’s own terms.

Licensing and Formation

TABC Licensing. Griffith & Hughes handles the entire licensing process for restaurants and bars, hotels and entertainment venues, convenience stores and gas stations, package stores, breweries, wineries and distilleries, and private clubs. It does more than submit applications: it identifies legal obstacles before they surface, structures entities to avoid Tied House violations, secures L-Cert certification from cities, counties, and the comptroller, and litigates when any of them refuse to comply. A recurring theme is the L-Cert problem most applicants discover too late: although AIMS lists local certification near the end of the process, the firm treats it as the first step, because gathering the city, county, and comptroller signatures takes the most time and the sequence varies by jurisdiction (for example, Dallas requires Dallas County to sign before the city will consider the application, while Tarrant County requires the reverse), and the comptroller will refuse to sign if any officer of the applicant entity has delinquent taxes, even taxes owed by a different, unrelated entity.

Alcohol Business Structuring and Formation. A license or permit may be held by a natural person (a sole proprietorship) or by a business entity such as a general partnership, limited partnership, corporation, or limited liability company. The firm advises on the tradeoffs, noting that a sole proprietorship exposes the individual owner to personal liability and cannot have a co-owner or partner, that undisclosed interests (a “silent partner”) are a serious criminal and administrative violation, and that a sole proprietor generally cannot transfer the permit on a sale, whereas a buyer of the equity of an entity can assume control of the permit if otherwise eligible. It also addresses entity conversions and the rules that allow a permit to carry over when ownership and management structure stay the same.

Private Club Formation. Drawing on the history of Texas alcohol regulation, from the Private Club Act of 1961 forward, the firm explains why a private club permit can still be the right path in partially dry areas or where a business cannot or does not want to meet restaurant requirements. A private club is member-owned: the members, not the business owner, own the club’s alcohol, and the structure typically involves two entities, a for-profit managing entity and a nonprofit (or unincorporated association) that holds the permit and operates the club. The club recoups alcohol costs through a member replenishment fee rather than a sale, and it must follow detailed membership, guest, and recordkeeping rules. By the firm’s account, it has formed hundreds of private clubs and prepares the required documents (bylaws, rules and regulations, management and sublease agreements, minutes, promissory notes, and more).

Concession and Management Agreements. The firm drafts and advises on the agreements that let a permittee keep exclusive control of its permit while a third party participates in operations. A Management and Service Agreement lets the license holder (the “BevCo”) contract with an operating company (the “OpCo”) to run alcohol sales and service for a fee, while the BevCo retains control of the premises, supplies the inventory, and takes the alcohol revenue. A Concession or Sublease Agreement lets a retailer operate at a third party’s location, such as a hotel, stadium, or event center, with a subtle distinction between the two turning on who owns the furniture, fixtures, and equipment. Throughout, the firm ties these structures to their statutory origins and stresses that they must be disclosed to the agency, with serious consequences for failure to comply.

Facilitating the Purchase and Sale of Businesses with Alcohol Permits. Buying a business in a regulated industry requires due diligence the firm walks through in detail: how the existing business is structured, whether the seller has provided a tax clearance letter (to avoid successor liability with the Comptroller), whether the seller’s ownership is current in AIMS, whether the parties intend an equity or asset purchase, whether the buyer and its officers, directors, shareholders, or investors are eligible, whether the permit is subject to a pending protest, disciplinary matter, investigation, or civil claim, and what must be reported to the agency and when. Some changes, the firm emphasizes, must be reported before an equity purchase and others within a set window after closing.

Variances to City Alcohol Distance Ordinances. Under Section 109.33 of the Code, cities and counties may adopt ordinances restricting alcohol sales near churches, schools, daycares, residences, and hospitals (commonly 300 feet, and up to 1,000 feet from schools in major metropolitan areas), and the Code prescribes how the measurements are taken (for example, property line to property line for schools, but front door to front door for churches and public hospitals). The firm disputes incorrect measurements before the County Judge and handles the variance process, which generally requires a denial first, then a variance application (sometimes with a fee), then a presentation to city council. It reports handling more than 100 variance requests statewide.

Texas Consumable Hemp Licensing and Registration. The firm helps manufacturers and retailers obtain the right authorizations from the Texas Department of State Health Services (DSHS) for consumable hemp products (CHP). It addresses what qualifies, the limits on smokable and vapable products, and the registration framework, noting (per its published materials) that a Retail Hemp Registration is generally required to sell CHP such as seltzers, edibles, and lotions, and that a broader Hemp Product License applies to activities that meet the DSHS definition of manufacturing. This is a fast-moving area: the firm itself flags that the status of certain cannabinoids may change based on a Texas Supreme Court decision expected in 2026, so the specifics here should be confirmed against current sources.

Disputes, Defense, and Compliance

TABC Violation Defense. The firm regularly defends hospitality businesses against alleged violations, which it groups into categories such as sale to an intoxicated person, sale to a minor, subterfuge, sale during prohibited hours, an intoxicated permittee or employee, inspection refusal, and failure to report or prevent a breach of the peace. A central tool is the Safe Harbor Defense, which a permit holder must assert within 10 days of receiving a Notice of Violation; successfully asserting it can result in the violation being restrained, meaning no suspension or penalty and no attribution to the business. From there, the firm weighs whether to settle or request a hearing, noting that a settlement can affect a parallel dram shop suit, and it first tries to get violations dismissed informally before proceeding to a hearing.

TABC Emergency Suspension Orders. The TABC can issue an Emergency Order of Suspension (EOS) to suspend a license or permit for up to 90 days where continued operation poses a continuing threat to the public welfare. The firm likens an EOS to a temporary restraining order and notes it can be used as leverage to coerce settlement of an underlying violation. A hearing must be held before an Administrative Law Judge at SOAH within 10 days of issuance, where the agency must prove by a preponderance of the evidence that reasonable cause existed, and the ALJ then issues a final, non-appealable order affirming, modifying, or setting aside the EOS. Because an EOS halts the ability to buy or sell alcohol while in effect, and the deadlines are tight, the firm stresses contacting counsel immediately, noting that remedial measures can make the difference between a one-day and a 90-day shutdown. Griffith & Hughes points to its successful EOS hearing during the COVID shutdowns as an example of this work.

Dram Shop Defense (Liquor Liability). The firm defends bars, restaurants, and other establishments against dram shop claims under Section 2.02 of the Code, which allows liability only where it was apparent the patron was obviously intoxicated and posed a clear danger when served, and the intoxication caused the injury. Defense strategies the firm describes include showing the patron was not apparently intoxicated when served, that intoxication was not caused by the alcohol or was not the proximate cause of the injuries, correctly asserting the Safe Harbor Defense, establishing comparative negligence, and simultaneously defending the TABC’s source investigation into the incident. It notes that its decades of TABC investigation and violation work feed directly into how it prepares these cases.

Comptroller Mixed Beverage Audits. Texas imposes both a 6.7% Mixed Beverage Gross Receipts Tax and an 8.25% Mixed Beverage Sales Tax on alcohol consumed on premises under a Mixed Beverage or Private Club permit. The firm defends businesses in audits by the Texas Comptroller, which uses an Alcoholic Beverage Depletion Analysis to estimate sales over a period that may reach four years, drawing on distributor and wholesaler reporting through the Retailer Inventory Tracking System (RITS) and generally presuming that all inventory purchased was resold absent records showing otherwise. Because that method often fails to account for theft, spillage, comps, inconsistent pours, ending inventory, and off-premise sales, assessments can reach tens or hundreds of thousands of dollars in tax, penalty, and interest. It has negotiated six-figure reductions on multiple such assessments, the firm reports.

TABC Audits. Separate from comptroller tax audits, the TABC periodically audits food and beverage certificate holders and private club permit holders. A food and beverage certificate audit checks whether a business has kept alcohol below 60% of gross revenue or otherwise meets the restaurant definition under the Code, and the firm helps clients stay compliant or find alternatives if alcohol sales run over. For private clubs, the agency typically conducts a routine audit within six months to a year after the permit issues, inspecting member and financial records and able to issue violations or cancel the permit for noncompliance; the firm draws on its experience forming clubs to prepare them for these audits.

City Alcohol Regulation. The Code generally preempts municipal regulation of alcohol except where it specifically allows cities and counties to act, and the firm fights local governments that exceed that authority. It explains the common carve-outs (such as distance from schools, churches, and hospitals, day-care proximity for certain retailers, and businesses deriving a high share of revenue from on-premise sales), the rule that a city cannot single out alcohol businesses except where the Code allows but can apply generally applicable ordinances, and the requirement that cities and counties certify an application within 30 days. When a municipality refuses to certify for an impermissible reason, the firm first sends a letter explaining preemption, then, if the refusal stands, pursues a hearing before the county judge and suit to compel certification.

Protests of Original or Renewal Applications. Since a 2018 TABC order (in the Core-Mark matter), the circumstances in which an application can be protested have been substantially narrowed. The firm explains who may now protest, including a defined list of state and local officials in the areas they represent, and members of the public only in specific circumstances (such as proximity within 300 feet, certain sexually oriented business situations, or large-municipality cases tied to revenue thresholds). It also explains that a protest does not automatically trigger a SOAH hearing: the agency investigates first and refers the matter to SOAH only if it finds reasonable grounds.

TABC Hearings. When a licensing determination or disciplinary action is not resolved informally, it may be set for hearing before an Administrative Law Judge at SOAH. The firm notes that, unlike civil and criminal cases, the Code and TABC rules do not set deadlines for agency licensing determinations, a statute of limitations on notices of violation, or time-for-hearing rights, and that after a proposal for decision and the exceptions process, the Commissioners issue an agency order on no fixed timeline (the firm reports seeing orders take anywhere from three to twelve months). It advises clients on whether to settle informally or proceed to a formal hearing.

How the Firm Handles a Licensing Matter

The firm describes a six-stage approach from strategy through approval:

Permit strategy and tier analysis. Determine which permits fit the business model and verify there are no Tied House conflicts before the client invests in a location.
Wet/dry and location verification. Confirm the proposed location is wet for the permit type, treating the TABC spreadsheet as a starting point rather than the final word, since only the city or county clerk can make an official determination.
L-Cert coordination. Manage the city, county, and comptroller certification sequence, including which jurisdictions sign first and how to resolve comptroller tax holds.
AIMS application filing. Prepare and submit the AIMS application with all required documentation, publication notices, and signage.
Issue resolution and litigation. When a city or county refuses to certify, first educate officials on their obligations, and if they still refuse, file suit to compel certification under the Code.
Post-approval compliance. Provide Safe Harbor Defense documentation, written alcohol policies, seller-server certification guidance, and comptroller audit preparation.

Permit Knowledge

The firm handles the common Texas retail and manufacturing permits and advises on the subordinate permits and certificates that often determine how a business operates. Among the points it highlights:

Food and Beverage Certificate (FB): attaches to retail permits such as MB, BG, and N; allows to-go alcohol sales with food; exempts the business from conduct surety bond requirements; and may eliminate the 51% firearms sign-posting requirement depending on the alcohol sales ratio. The firm notes that, as of January 2022 under SB 911, businesses with permanent commercial cooking equipment and multiple entrees qualify as a “restaurant” under the Code and are exempt from the 60% alcohol sales cap.
Late Hours Permit (LH): allows alcohol service between midnight and 2:00 AM, with availability depending on local population thresholds or city/county ordinance.
Brewpub License (BP): attaches to MB, BG, or BE and authorizes on-site beer manufacturing and sales.
Tied House restriction: Texas prohibits holding interests across more than one tier (retail, distribution, manufacturing), and the firm verifies tier compliance before a client applies, to prevent permanent structural violations.

Track Record and Notable Points

The figures below are as stated in the firm’s own materials.

85+ years of combined TABC experience across the team, and more than 400 cases handled before SOAH, county courts, district courts, and appellate courts.
A successful emergency suspension order hearing during the COVID shutdowns, described as one of the only such successful hearings in the state.
Six-figure reductions negotiated on multiple comptroller mixed beverage tax audit assessments.
Hundreds of private clubs formed and more than 100 distance variance requests handled statewide.
From the founding attorney’s TABC tenure: $665,892 in civil penalties litigated and involvement in the cancellation or denial of 128 permits, including one of the largest civil penalties in TABC history.

Insights and Thought Leadership

The firm publishes on developments in alcohol and adjacent regulation. Recent pieces include:

“158-Year-Old Federal Ban Against Home Distilling Held to be Unconstitutional”, on the recent appellate ruling striking down the longstanding federal home-distilling prohibition and what it does and does not change for Texas.
“Navigating the Haze of Current Consumable Hemp Product Regulations”, on the shifting framework governing consumable hemp products in Texas.
“Death Penalty Sanctions for Liquor Permit for a Single Non-Compliant Sale of Consumable Hemp Products”, on how a single non-compliant hemp sale can expose a liquor permit to the most severe sanction.

Because the hemp, THC, and home-distilling areas are evolving quickly and parts remain subject to court action, the positions in these pieces should be confirmed against current sources.

Office and Contact

Griffith & Hughes PLLC 2225 E Randol Mill Road, Suites 110 & 106 Arlington, TX 76011 (Arlington Downs Tower, the same building as the TABC Dallas/Fort Worth Regional Office)

Phone: 817-562-9648 Email: info@griffithhughes.com Online: Facebook (TABClawattorneys), LinkedIn, Instagram (@liquor_lawyer)

The firm serves clients throughout Texas and notes that communication through its website does not establish an attorney-client relationship.

This profile was compiled from Griffith & Hughes PLLC’s published website content (firm overview, practice-area pages, and attorney and staff biographies) as of June 2026. Track-record figures, credentials, and matter references reflect the firm’s own stated materials. Regulatory specifics, particularly in the consumable hemp and home-distilling areas, are evolving and should be confirmed against current primary sources.