Falls County Appraisal District, Allen McKinley and Andrew J. Hahn v. Wally R. and Voncyle Rusty Burns

CourtCourt of Appeals of Texas
DecidedMarch 23, 2022
Docket10-21-00119-CV
StatusPublished

This text of Falls County Appraisal District, Allen McKinley and Andrew J. Hahn v. Wally R. and Voncyle Rusty Burns (Falls County Appraisal District, Allen McKinley and Andrew J. Hahn v. Wally R. and Voncyle Rusty Burns) 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
Falls County Appraisal District, Allen McKinley and Andrew J. Hahn v. Wally R. and Voncyle Rusty Burns, (Tex. Ct. App. 2022).

Opinion

IN THE TENTH COURT OF APPEALS

No. 10-21-00119-CV

FALLS COUNTY APPRAISAL DISTRICT, ALLEN MCKINLEY, AND ANDREW J. HAHN, Appellants v.

WALLY R. AND VONCYLE RUSTY BURNS, Appellees

From the 82nd District Court Falls County, Texas Trial Court No. CV40782

MEMORANDUM OPINION

The Falls County Appraisal District (FCAD), Allen McKinley, and Andrew J. Hahn

bring this interlocutory appeal challenging the trial court’s denial of their third amended

motion for summary judgment. We will affirm in part and reverse in part. Factual and Procedural Background

Wally and Voncyle Burns (the Burnses) sued FCAD, McKinley (the former chief

appraiser), and Hahn (the current chief appraiser), alleging in relevant part as follows in

their live petition:

IV. BACKGROUND FACTS

....

8. [The Burnses] understand the pressure faced by appraisal districts all over Texas to increase property assessed values, and property owners throughout the state have been feeling the effects of that pressure for several years. However, neither the chief appraiser nor appraisal district has been authorized by law, rule or written guidance of the Comptroller of Public Accounts to simply “make up” assessments which impose arbitrary burdens on property owners – specifically rural homestead owners – in order to increase assessed values on property within the appraisal district.

9. In late summer of 2019, [the Burnses] discovered that the Chief Appraiser at the time (Allen McKinley) and [FCAD] had, for the first time, identified an alleged “improvement” on [the Burnses’] rural homestead, described it as “HS UTILITIES”, and assigned a predetermined flat value of an additional $6,000.00 to manipulate the overall assessed value on [the Burnses’] property. A true and correct copy of the property appraisal information published by Defendant is attached hereto as Exhibit “A”.

10. On September 16, 2019, [the Burnses] sent a letter to the Falls County Appraisal Board, attention to Larry Boone (the chairman at the time), with a copy to the Chief Appraiser (Allen McKinley) concerning this unusual assessment. A true and correct copy of that letter is attached hereto as Exhibit “B”. That letter attempted to summarize the events and positions that had been articulated at the August 22, 2019, Board Meeting at which the FCAD Board Chairman stated the position of [FCAD]. He asserted that the $6,000.00 property improvement assessment for rural homesteads was Falls Cnty. Appraisal Dist. v. Burns Page 2 because utilities provided “added value” to rural homestead property. As reflected in [the Burnses’] letter of September 16, 2019, however:

(a) Rural and incorporated homesites obtain their utilities from water mains and electrical transmission lines provided in the utility easement adjacent to the property. Property owners are responsible for making arrangement for connection to the utilities. Rural property does not gain “added value” over and above incorporated property when connecting to utilities.

(b) The difference between rural and incorporated areas is the supplier. The water utility in rural areas is supplied by a Water Supply Corporation (“WSC”) while the water utility in the incorporated areas is supplied by city utilities. The development and maintenance of a water utility is provided through water rates in both cases. There is no “added value” to either property classification. Because of population density, water usage rates for WSC customers is [sic] typically double that of customers in incorporated areas. Marlin is the one exception due to the ongoing water infrastructure crises, resulting in higher water fees.

(c) When listing a rural property, realtors must disclose to prospective buyers if a homesite is dependent on the use of a septic system because the property becomes less desirable due to the recurring maintenance cost and not “added value” to the property.

(d) The “Homestead Utilities” property improvement assessment imposed on [the Burnses’] rural homestead is arbitrary and is not being applied equally to all properties in Falls County.

In summary, there is no “added value” to rural homesites for having utilities over homesites in incorporated areas. The added improvement of Homestead Utilities for rural homesteads is an unlawful arbitrary assessment not based on evidence as required by the guidelines of the Texas Property Tax Code.

Falls Cnty. Appraisal Dist. v. Burns Page 3 11. Under Section 23.23 of the Texas Property Tax Code, there is a limitation on appraised value of a residence homestead. When appraising a residence homestead, the Chief Appraiser shall appraise the property at its market value. According to Section 23.23(e), a “new improvement” means an improvement to a residence homestead made after the most recent appraisal of the property that increases the market value of the property and the value of which is not included in the appraised value of the property for the preceding tax year.

12. Here, Allen McKinley, the Chief Appraiser at the time, acting outside his legal authority, assigned a new improvement, “HS UTILITIES” with a flat value of $6,000.00 to [the Burnses’] real property – which obviously is not a “new” improvement.[1] When pressed on the issue, no person at [FCAD], including the former and current Chief Appraiser, has been able to identify a statutory, regulatory or factual basis for arbitrarily assigning a $6,000.00 assessment to rural homestead owners only. Common sense compels the conclusion that “utilities” at a rural homestead are not an “improvement” subject to additional tax assessment over and above the structures served by those utilities.

13. The current Chief Appraiser, Andrew Hahn, and [FCAD] have continued to unlawfully impose/assign the “HS UTILITIES” assessment to [the Burnses’] property in 2020, despite having been given the opportunity to correct the unlawful assessment.

14. Then, by Order Determining Protest dated August 4, 2020 (copy attached as Exhibit “C”), less than 60 days prior to the filing of this Third Amended Petition, [FCAD] denied [the Burnses’] protest concerning the 2020 appraisal on the same property, where they specifically challenged to continued imposition of assessment for “HS UTILITIES”. This action is an appeal of that assessment under Tex. Tax Code § 42.21.

1 A footnote in the petition here states:

Based on information obtained by way of an Open Records Request, [the Burnses] have learned that this arbitrary $6,000.00 “HS Utilities” flat assessment has been added to nearly 2800 rural property owners in Falls County – the effect of which has been an increase in each property owner’s tax bill in excess of $100.00 for 2019. This “hidden tax” is unauthorized, unlawful, and unacceptable.

Falls Cnty. Appraisal Dist. v. Burns Page 4 V. REQUEST FOR DECLARATORY RELIEF AND RELIEF UNDER THE TEXAS TAX CODE

15. [The Burnses] request that the Court declare that the designated “Improvement” contained on [the Burnses’] Falls County property for “HS UTILITIES” for the flat value of “$6,000.00” beginning in 2019 (and now continuing into 2020), is unauthorized, arbitrary and/or unlawful and excessive, and cannot form the basis for an added assessment on [the Burnses’] (or any other rural homestead owners) property. The Chief Appraisers acted beyond the scope of their authority and [FCAD] has failed, despite requests, to reverse the unlawful action taken by its Chief Appraisers.

FCAD, McKinley, and Hahn (collectively, Appellants) subsequently moved for

traditional summary judgment. In their third amended motion for summary judgment,

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Kentucky v. Graham
473 U.S. 159 (Supreme Court, 1985)
Texas Department of Parks & Wildlife v. Miranda
133 S.W.3d 217 (Texas Supreme Court, 2004)
Harris County v. Sykes
136 S.W.3d 635 (Texas Supreme Court, 2004)
Matagorda County Appraisal District v. Coastal Liquids Partners
165 S.W.3d 329 (Texas Supreme Court, 2005)
City of Houston v. Williams
216 S.W.3d 827 (Texas Supreme Court, 2007)
Texas a & M University System v. Koseoglu
233 S.W.3d 835 (Texas Supreme Court, 2007)
The City of El Paso v. Lilli M. Heinrich
284 S.W.3d 366 (Texas Supreme Court, 2009)
City of Dallas v. Carbajal
324 S.W.3d 537 (Texas Supreme Court, 2010)
Franka v. Velasquez
332 S.W.3d 367 (Texas Supreme Court, 2011)
Travis Central Appraisal District v. Norman
342 S.W.3d 54 (Texas Supreme Court, 2011)
Texas Natural Resource Conservation Commission v. IT-Davy
74 S.W.3d 849 (Texas Supreme Court, 2002)
Cathey v. Booth
900 S.W.2d 339 (Texas Supreme Court, 1995)
Cameron Appraisal District v. Rourk
194 S.W.3d 501 (Texas Supreme Court, 2006)
Covert v. Williamson Central Appraisal District
241 S.W.3d 655 (Court of Appeals of Texas, 2007)
Cloud v. McKinney
228 S.W.3d 326 (Court of Appeals of Texas, 2007)
Prairie View A&M University v. Diljit K. Chatha
381 S.W.3d 500 (Texas Supreme Court, 2012)
Texas Parks & Wildlife Department v. Sawyer Trust
354 S.W.3d 384 (Texas Supreme Court, 2011)

Cite This Page — Counsel Stack

Bluebook (online)
Falls County Appraisal District, Allen McKinley and Andrew J. Hahn v. Wally R. and Voncyle Rusty Burns, Counsel Stack Legal Research, https://law.counselstack.com/opinion/falls-county-appraisal-district-allen-mckinley-and-andrew-j-hahn-v-wally-texapp-2022.