Bryan Independent School District and Brazos County v. Brad Cune

CourtCourt of Appeals of Texas
DecidedJune 24, 2010
Docket14-09-00062-CV
StatusPublished

This text of Bryan Independent School District and Brazos County v. Brad Cune (Bryan Independent School District and Brazos County v. Brad Cune) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bryan Independent School District and Brazos County v. Brad Cune, (Tex. Ct. App. 2010).

Opinion

Reversed and Rendered and Memorandum Opinion filed June 24, 2010.

In The

Fourteenth Court of Appeals

NO. 14-09-00062-CV

Bryan Independent School District and Brazos County, Appellants

V.

Brad Cune, Appellee

On Appeal from the 272nd District Court

Brazos County, Texas

Trial Court Cause No. 48867-CV

MEMORANDUM OPINION

       Appellants, Bryan Independent School District and Brazos County, appeal an order awarding excess proceeds from a property-tax foreclosure sale to appellee, Brad Cune, as assignee of the purported former property owner, George Earl Jenkins.  In three issues, appellants contend Cune did not prove the assignor was entitled to the excess proceeds and Cune failed to claim the proceeds within the time period prescribed by statute.  We reverse and render.

I.         Background

In 1999, appellants sued George Earl Jenkins, Delores Jenkins, and Vernell King, alleging they owned or had an interest in certain real property on which taxes were delinquent and seeking foreclosure of appellants’ tax lien.[1]  On November 30, 2000, the trial court signed a judgment ordering foreclosure and sale of the property.  The sale was conducted on May 6, 2003.  After disbursement of proceeds for payment of past due taxes and various fees associated with the sale, there remained excess proceeds of $14,781.86, which the sheriff paid to the district clerk.  Within thirty days after receipt of the excess proceeds, the district clerk sent documents entitled “Notice of Excess Funds,” via certified mail, return receipt requested, to the defendants at the addresses set forth in the petition and to all parties’ attorneys.

On March 26, 2008, Cune filed a “Motion To Release Excess Proceeds Subject To Tax Code §34.04 Via Assignment,” alleging that “George Earl Jenkins” assigned the right to excess proceeds to Cune and attaching an affidavit of assignment.  Each appellant filed pleadings, asserting Cune’s claim was barred by the statute of limitations and requesting that it be paid the excess proceeds.

On September 11, 2008, the trial court held a hearing on Cune’s motion and, at the conclusion, announced that it granted the motion.  On the same day, the trial court signed an order awarding the excess proceeds to Cune.  Appellants filed a motion for new trial.  At a hearing, the trial court orally denied the motion but did not sign a written order.

II.        Analysis

A.        Applicable Law

     Chapter 34 of the Texas Tax Code prescribes the procedures for tax sales and redemption.  See Tex. Tax Code Ann. §§ 34.01–34.23 (Vernon 2008 & Supp. 2009).  Proceeds of a tax sale are applied first to various expenses associated with the tax suit and sale, then to the taxing unit for certain expenses, and then to taxes, penalties, interest, attorney’s fees, and other amounts awarded under the judgment.  Id. § 34.02(a).  Excess proceeds are paid to the clerk of the court issuing the warrant or order of sale.  See id. § 34.02(d).

    Section 34.03 imposes certain duties on the clerk of the court with respect to “Disposition of Excess Proceeds.”  The clerk is required to perform the following actions upon receipt of excess proceeds:

(1) if the amount of excess proceeds is more than $25, before the 31st day after the date the excess proceeds are received by the clerk, send by certified mail, return receipt requested, a written notice to the former owner of the property, at the former owner’s last known address according to the records of the court or any other source reasonably available to the court, that:

            (A) states the amount of the excess proceeds;

            (B) informs the former owner of that owner’s rights to claim the excess proceeds under Section 34.04;  and

            (C) includes a copy or the complete text of this section and  Section 34.04;  and

(2) regardless of the amount, keep the excess proceeds . . . for a period of two years after the date of the sale unless otherwise ordered by the court.

Id. § 34.03(a).

Section 34.04 governs “Claims for Excess Proceeds.”  A person, including a taxing unit, may file a petition in the court that ordered the seizure or sale setting forth a claim to the excess proceeds.  Id. § 34.04(a).  The petition must be filed before the second anniversary of the date of the sale of the property.  Id.  At the hearing, the trial court must order that the excess proceeds be paid according to certain priorities to each party “that establishes its claim to the proceeds.”  Id. § 34.04(c).  The last payee outlined in the list of priorities is “each former owner of the property, as the interest of each may appear . . . .”  Id. § 34.04(c)(5).[2]  Further, a former owner may assign his interest in excess proceeds to another person if certain requisites are satisfied.  See id. § 34.04(f)–(h).  An order under this section directing that all or part of the excess proceeds be paid to a party is appealable.  Id. § 34.04(e).

Finally, under section 34.03(b), if no claimant establishes entitlement to the proceeds within two years from the date of sale, “the clerk shall distribute the excess proceeds to each taxing unit participating in the sale in an amount equal to the proportion its taxes, penalties, and interests bear to the total amount of taxes, penalties, and interest due all participants in the sale.”  Id. § 34.03(b).   

B.        Issues

In their first issue, appellants contend Cune failed to establish his claim to the proceeds, as assignee of Jenkins, because he failed to prove Jenkins was a former owner of the property or the amount of his ownership interest, considering there were several defendants to the delinquent-tax suit.  See id. § 34.04(c).  Appellants’ second and third issues are interrelated and concern their contention that Cune was not entitled to the proceeds because he failed to file his motion within two years after sale of the property.  See id.

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Bryan Independent School District and Brazos County v. Brad Cune, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bryan-independent-school-district-and-brazos-count-texapp-2010.