Background: Texas does not require health education or tobacco use prevention education (TUPE) in its middle schools. During planning for the Texas Tobacco Prevention Initiative, this baseline research was conducted to (1) describe tobacco prevention and control practices in middle schools prior to the pilot, (2) analyze implementation of a state law prohibiting tobacco use on campuses and at school events, and (3) identify how schools are influenced by district policies requiring health education. Methods: Written surveys derived from the 2000 School Health Education Profile Tobacco Module developed by the Centers for Disease Control and Prevention were completed by principals and health coordinators at schools in districts requiring health education (n = 31) and schools without district requirements (n = 32). Results: School tobacco policy familiarity and enforcement were consistently reported in response to a state law with rigorous recommendations prohibiting tobacco use. Significantly more activity in numerous components of TUPE was reported in schools in districts with a health education requirement. Conclusions: Results have implications for intervention programs planned in schools located in states seeking to develop or strengthen state laws, or in states without health education or specific health content requirements.