George Long v. Atascosa Central Appraisal

CourtCourt of Appeals of Texas
DecidedApril 30, 2025
Docket04-24-00217-CV
StatusPublished

This text of George Long v. Atascosa Central Appraisal (George Long v. Atascosa Central Appraisal) 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
George Long v. Atascosa Central Appraisal, (Tex. Ct. App. 2025).

Opinion

Fourth Court of Appeals San Antonio, Texas MEMORANDUM OPINION

No. 04-24-00217-CV

George LONG, Appellant

v.

ATASCOSA CENTRAL APPRAISAL DISTRICT, Appellee

From the 81st/218th Judicial District Court, Atascosa County, Texas Trial Court No. 23-04-0253-CVA Honorable Russell Wilson, Judge Presiding

Opinion by: Velia J. Meza, Justice

Sitting: Rebeca C. Martinez, Chief Justice Lori Massey Brissette, Justice Velia J. Meza, Justice

Delivered and Filed: April 30, 2025

AFFIRMED IN PART, REVERSED AND REMANDED IN PART

George Long appeals the trial court’s order granting a plea to the jurisdiction filed by the

Atascosa Central Appraisal District (“ACAD”) and dismissing his petition claiming ACAD failed

to notify him of the removal of an open-space appraisal on his land for the 2022 ad valorem tax

year. We affirm the trial court’s judgment in part, reverse and remand in part. 04-24-00217-CV

BACKGROUND

The property that is the subject of this appeal is identified in the Atascosa County Appraisal

District, or ACAD, records under Property ID number 217606 (the “Property”). George Long

purchased the Property on January 30, 2022, from his niece Rachel Long. Ms. Long, the prior

owner, was deeded the Property upon the death of Norman Long on December 31, 2021. For many

years under the ownership of Norman Long, the Property was used exclusively for wildlife

management and, therefore, qualified as open-space land under section 23.51 of the Texas Tax

Code. As open-space land, and more specifically, a “1-d-1 open-space wildlife management

valuation,” the tract was appraised, for tax purposes, at less than market value under what is

commonly referred to as the agricultural use exemption. See TEX. TAX CODE §§ 23.51–23.60.

The deed reflecting the purchase of the Property by George Long was recorded in the

official deed records of the Atascosa County Clerk’s office on February 1, 2022. The deed listed

George Long’s correct mailing address. According to his affidavit, George Long called the ACAD

office “on or before March 11, 2022” and spoke to an employee in charge of deed record changes.

She was aware he had purchased the Property. Long asked her whether he needed to take any

action to maintain the 1-d-1 open-space valuation for 2022. She told Long he “had two years to

submit a new wildlife management plan and application.” She did not mention any plans to “pull”

the 1-d-1 open-space wildlife management valuation. In its pleadings, ACAD attached the affidavit

of the Chief Appraiser Michelle Berdeaux whereby she denied her employee made those

statements. In fact, the affiant alleged that she had “personal knowledge that [Long] was told …

that as a new property owner, pursuant to section 23.54 of the Property Tax Code, he is required

to file a new application.” There is no evidence in the record that shows what date or through what

means this information was transmitted to Long

-2- 04-24-00217-CV

The record reflects ACAD updated its ownership records to show Rachel Long as owner

of the Property on March 12, 2022. Three days later, ACAD updated its ownership records to show

George Long as owner of the Property on March 15, 2022. On March 15, 2022, however, ACAD

only mailed a Notice of Open Space Removal to Rachel Long. The notice stated:

Our records indicate the [Property] requires a new application to be filed to continue receiving the Special Open Space, or 1-D-1 productivity valuation. This letter is notification that the Special Open Space, or 1-D-1 valuation, has been removed. Property owners must file an application in order to receive the special use valuation. Failure to do so will result in the subject property being assessed at market value for the 2022 tax year.

The deadline for filing the new application was listed as April 30, 2022, with late

applications subject to a penalty. According to his affidavit, George Long never received the

Notice of Open Space Removal. It is undisputed that no application for open-space appraisal was

filed by either Rachel or George Long during 2022.

On May 17, 2022, ACAD mailed the 2022 Notice of Appraised Value (“NOAV”) for the

Property to George Long at his correct address. The NOAV showed a “0” value for “Ag/Timber

Land” and “0” value for “productivity value of Ag/Timber Land” and an appraised value of

$680,000 based on “Market Value of Non Ag/Timber Land.” 1 The NOAV stated the deadline to

file a protest of the appraised value was June 17, 2022. According to his affidavit, Long did not

see the NOAV until the Fall because he was out of state. 2 When Long received his 2022 tax bill

from ACAD in the Fall, he noticed the absence of the open-space valuation and high tax bill based

on the Property’s market value. Long called ACAD to inquire and was informed the tax roll was

already certified and it was too late to file a protest for the 2022 tax year.

1 Open-space appraisal is colloquially referred to as “Ag” for “Agricultural appraisal.” 2 In his brief, Long states that he splits his time between Texas and Alaska.

-3- 04-24-00217-CV

On December 30, 2022, Long filed a late protest pursuant to section 41.411 of the Tax

Code based on ACAD’s “failure to send notice” of “denial of open-space valuation.” Long also

sought to correct clerical errors in the acreage and legal description of the Property.

On February 15, 2023, the Appraisal Review Board (“ARB”) held a hearing on Long’s

section 41.411 late protest. The appellate record in this case does not contain a transcript of the

ARB hearing or its written order. However, the fact that such a hearing occurred is uncontested.

Without a written determination of his protest from the ARB, Long sought judicial review

of the ARB’s determination and filed an original petition in the district court pursuant to Texas

Tax Code § 42.01. Long challenged ACAD’s “failure to send notice” of its intent to remove the

open-space valuation and its “erroneous rejection of Plaintiff’s 2022 qualification for 1-d-1 open-

space valuation.” Long also requested correction of clerical errors in the Property’s legal

description.

ACAD initially filed a general denial on June 20, 2023, then subsequently filed a plea to

the jurisdiction on November 13, 2023. ACAD asserted that by failing to file an open-space

appraisal application and timely protest the 2022 appraised value, Long had failed to exhaust his

administrative remedies thereby depriving the court of subject matter jurisdiction.

After hearing arguments and considering the pleadings and evidence, the trial court ruled

that Long failed to exhaust his administrative remedies as required by the Tax Code and therefore

it lacked subject matter jurisdiction to consider his petition. The trial court granted ACAD’s plea

to the jurisdiction and dismissed Long’s petition with prejudice. Long appealed.

-4- 04-24-00217-CV

STANDARD OF REVIEW

We review a trial court’s determination of subject matter jurisdiction and ruling on a plea

to the jurisdiction de novo. Tex. Dep’t Parks & Wildlife v. Miranda, 133 S.W.3d 217, 227 (Tex.

2004). “In deciding a plea to the jurisdiction, a court may not weigh the claims’ merits but must

consider only the plaintiffs’ pleadings and the evidence pertinent to the jurisdictional inquiry.”

Cnty. of Cameron v.

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