Occasionally, they do get it right…
Curlee v. State (PD-20-0624-20)(Texas Court of Criminal Appeals)(April 14, 2021): a playground on the premises of a church which is surrounded by chain-link fence and padlock that was not completely locked (but nevertheless showed an intention to lock the playground) is not “open to the public” for purposes of the drug-free zone enhancement (See Drug Free Zone enhancement)