Exxon Mobil Global Services v. State Office of Administrative Hearings, and Keneshia Washington in Her Official Capacity as Administrative Law Judge

Court of Appeals of Texas·Decided May 6, 2025·No. 15-24-00034-CV·Published

Opinion

ACCEPTED 15-24-00034-CV FIFTEENTH COURT OF APPEALS TRACY M. TURNER AUSTIN, TEXAS ATTORNEY 5/6/2025 1:51 PM TEXAS STATE BAR NO. 24076743 CHRISTOPHER A. PRINE TRACY@TEXASPROPERTYTAXATTORNEYS.COM CLERK DIRECT 214.935.9477 FILED IN 15th COURT OF APPEALS AUSTIN, TEXAS May 6, 2025 5/6/2025 1:51:52 PM CHRISTOPHER A. PRINE Via Electronic Service Provider Clerk

Mr. Christopher A. Prine Clerk of the Court Fifteenth Court of Appeals P.O. Box 12852 Austin, Texas 78711

Re: Exxon Mobil Global Services v. State Office of Administrative Hearings, et al. No. 15-24-00034-CV, in the Fifteenth Court of Appeals

Dear Mr. Prine,

As requested by Justice Farris during oral argument on April 15, 2025, in the above-referenced case, Exxon submits this post-submission letter to provide any preexisting case law addressing classification issues heard by SOAH. Although the Texas Administrative Code provides that classification disputes may be appealed to SOAH, I have been unable to locate any case in which a school district has done so.

The ability to appeal classification errors is set out in 34 TAC § 9.101(g)(6)(C), which provides:

Appraisers shall categorize sample properties as they are categorized by appraisal districts (Category A, B, C, etc.), unless the comptroller determines that a property or portion of property is categorized incorrectly, in which case the comptroller may move the value of the property into the correct category. The comptroller's decision to re-categorize property may be the subject of a protest provided by Government Code, §403.303.

At present, it appears that while the regulatory framework allows for such appeals, there is no reported case law illustrating how this process has been applied in practice.

Sincerely,

Tracy M. Turner

cc: Ms. Karen L. Watkins (via e-service) cc: Ms. Caroline Tom (via e-service)

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Tracy Turner on behalf of Tracy Turner Bar No. 24076743 Tracy@TexasPropertyTaxAttorneys.com Envelope ID: 100498149 Filing Code Description: Letter Filing Description: Exxon's Post Submission Brief Status as of 5/6/2025 2:22 PM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Jeff Lutz jeff.lutz@oag.texas.gov 5/6/2025 1:51:52 PM SENT

Karen Watkins karen.watkins@oag.texas.gov 5/6/2025 1:51:52 PM SENT

John Brusniak john@texaspropertytaxattorneys.com 5/6/2025 1:51:52 PM SENT

Tracy Turner tracy@texaspropertytaxattorneys.com 5/6/2025 1:51:52 PM SENT

Lauren Brusniak lauren@texaspropertytaxattorneys.com 5/6/2025 1:51:52 PM SENT

Kendal Carnley kendal@texaspropertytaxattorneys.com 5/6/2025 1:51:52 PM SENT

Caroline Tom ctom@olsonllp.com 5/6/2025 1:51:52 PM SENT

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Mr. Christopher A. Prine Clerk of the Court Fifteenth Court of Appeals P.O. Box 12852 Austin, Texas 78711

Re: Exxon Mobil Global Services v. State Office of Administrative Hearings, et al. No. 15-24-00034-CV, in the Fifteenth Court of Appeals

Dear Mr. Prine,

The ability to appeal classification errors is set out in 34 TAC § 9.101(g)(6)(C), which provides:

Appraisers shall categorize sample properties as they are categorized by appraisal districts (Category A, B, C, etc.), unless the comptroller determines that a property or portion of property is categorized incorrectly, in which case the comptroller may move the value of the property into the correct category. The comptroller's decision to re-categorize property may be the subject of a protest provided by Government Code, §403.303.

At present, it appears that while the regulatory framework allows for such appeals, there is no reported case law illustrating how this process has been applied in practice.

Sincerely,

Tracy M. Turner

cc: Ms. Karen L. Watkins (via e-service) cc: Ms. Caroline Tom (via e-service)

P. O. B O X 7 0 3 2 3 8 | D A L L A S T X 7 5 3 7 0 | 2 1 4. 2 9 5. 6 0 9 5

WWW.T E X A S P R O P E R T Y T AX A T T O R N E Y S . COM

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Jeff Lutz jeff.lutz@oag.texas.gov 5/6/2025 1:51:52 PM SENT

Karen Watkins karen.watkins@oag.texas.gov 5/6/2025 1:51:52 PM SENT

John Brusniak john@texaspropertytaxattorneys.com 5/6/2025 1:51:52 PM SENT

Tracy Turner tracy@texaspropertytaxattorneys.com 5/6/2025 1:51:52 PM SENT

Lauren Brusniak lauren@texaspropertytaxattorneys.com 5/6/2025 1:51:52 PM SENT

Kendal Carnley kendal@texaspropertytaxattorneys.com 5/6/2025 1:51:52 PM SENT

Caroline Tom ctom@olsonllp.com 5/6/2025 1:51:52 PM SENT

Exxon Mobil Global Services v. State Office of Administrative Hearings, and Keneshia Washington in Her Official Capacity as Administrative Law Judge, (Tex. Ct. App. 2025).

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Exxon Mobil Global Services v. State Office of Administrative Hearings, and Keneshia Washington in Her Official Capacity as Administrative Law Judge (Exxon Mobil Global Services v. State Office of Administrative Hearings, and Keneshia Washington in Her Official Capacity as Administrative Law Judge) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.