"As a rule, . . . the names of complainants are public information. . . . Only in unusual instances, such as where the complainant was the victim of a sexual assault may the identity of a complainant be withheld." Tex. Att'y Gen. ORD-482 (1987) (citations omitted); see Houston Chronicle Publ'g Co., 531 S.W.2d at 186-87 (finding a constitutionally protected right of the press to the front page of offense reports, including, among other things, the identity and description of the complainant); see also Tex. Att'y Gen. Nos. ORD-611 (1992) (advising that documents relating to a police department's investigation of
adult victims of family violence are likewise not per se excepted from disclosure), ORD-440 (1986) (advising that the investigation file on alleged child abuse at a state school for the deaf is excepted), ORD-422 (1984) (advising that the identity of a shooting victim is not per se excepted by common law privacy), ORD-409 (1984) (advising that the names of burglary victims are not ordinarily excepted from disclosure), ORD-393 (1983) (advising that the identity of a child who may have been sexually abused is excepted by common law privacy), ORD-339 (1982) (opining that "common law privacy permits the withholding of the name of every victim of a serious sexual offense"); see also In re Westwood Affiliates, L.L.C., 263 S.W.3d 176 (Tex. App.—Houston [1st Dist.] 2007, orig. proceeding) (Mother of shooting victim who brought premises liability action against owner of the retail establishment outside of which the shooting occurred not entitled to police department’s murder investigation records because such records are exempted by the law-enforcement privilege).
Article 57.02 of the Texas Code of Criminal Procedure allows victims of sex crimes to use pseudonyms in all public records concerning the offense, including in police reports and during testimony in court. Under this law, law enforcement officials cannot disclose the victim's name, address or telephone number unless ordered to do so by a court. Tex. Crim. Proc. Code Ann. art. 57.02.