Harris Central Appraisal District F/K/A Harris County Appraisal District v. Houston Pipe Line Co LP

CourtCourt of Appeals of Texas
DecidedDecember 10, 2024
Docket01-23-00839-CV
StatusPublished

This text of Harris Central Appraisal District F/K/A Harris County Appraisal District v. Houston Pipe Line Co LP (Harris Central Appraisal District F/K/A Harris County Appraisal District v. Houston Pipe Line Co LP) 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
Harris Central Appraisal District F/K/A Harris County Appraisal District v. Houston Pipe Line Co LP, (Tex. Ct. App. 2024).

Opinion

Opinion issued December 10, 2024

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-23-00839-CV ——————————— HARRIS CENTRAL APPRAISAL DISTRICT F/K/A HARRIS COUNTY APPRAISAL DISTRICT, Appellant V. HOUSTON PIPE LINE CO LP, Appellee

On Appeal from the 333rd District Court Harris County, Texas Trial Court Case No. 2023-05899

O P I N I O N

In this accelerated interlocutory appeal arising out of an ad valorem tax

dispute, Harris Central Appraisal District, formerly known as Harris County

Appraisal District, challenges the trial court’s order denying its jurisdictional plea.

We affirm. BACKGROUND

Houston Pipe Line Co LP filed suit against Harris Central Appraisal District

in a Harris County district court on January 30, 2023, appealing from an appraisal

review board’s 2022 valuation of its stored natural gas for ad valorem tax purposes.

Among other things, Houston Pipe Line Co alleged that it did not receive timely

notice from the board of the August 29, 2022 appraisal order it sought to appeal.

Harris Central Appraisal District filed a plea to the jurisdiction. In its plea, the

District asserted that Houston Pipe Line Co failed to appeal from the appraisal

review board’s order within 60 days as required by statute. Because this statutory

deadline is jurisdictional, the District argued that the appeal had to be dismissed.

In support of its jurisdictional plea, the District filed the declaration of

Varmika Johnson, the manager assigned to the operations division of the appraisal

review board. Johnson declared that the board issued its appraisal order on August

29, 2022, and sent a copy to Houston Pipe Line Co’s designated representative that

same day via certified mail. Johnson further declared that the United States Postal

Service’s online tracking system showed the copy was delivered as addressed.

Johnson attached several documents to her declaration, which she declared

were filed, kept, or created by the District as required by law. In addition, Johnson

declared that these documents satisfied the requisites of the business records

exception to the rule of evidence that otherwise renders hearsay inadmissible.

2 Included among the documents attached to Johnson’s declaration were: the

August 29, 2022 appraisal board order; a log created by the District and dated August

20, 2022, that documents the certified mailings made by the District, including the

mailing of the written order in question; and a screenshot from the United States

Postal Service’s website tracking the mailing and delivery of the written order.

Houston Pipe Line Co filed a response in which it disputed that it

contemporaneously received the August 29, 2022 order. The company maintained

that in response to its suit in the district court, which initially named both the District

and the appraisal review board as defendants, the company and the board entered

into a settlement, under which the board resent the appraisal order at issue. Houston

Pipe Line Co argued that its appeal was filed timely relative to when it actually

received the resent order, thereby satisfying the statute’s jurisdictional deadline.

In support of its position, Houston Pipe Line Co submitted the declaration of

Kyle Fisher, the corporate representative of KE Andrews, which is the tax-

consulting firm that Houston Pipe Line Co designated as its agent in tax disputes.

Fisher declared that KE Andrews uses a “comprehensive, sophisticated,

automated and audited system” regarding its clients’ tax disputes. This system is

designed to ensure “the proper receipt, processing and handling of mail.” According

to Fisher, in the firm’s 45-year history, there has not been a single documented case

in which the firm “failed to properly and timely handle a tax-related notice.”

3 Fisher further declared that KE Andrews “did not receive the ARB’s order”

at issue. After discovering that it had not received the order, the firm notified

Houston Pipe Line Co, which appealed from the appraisal review board order in the

Harris County district court and contested receipt of the order as part of its appeal.

As a result, the appraisal review board resent its order on March 20, 2023.

Fisher opined that the firm “can say with certainty” that it did not receive the

order before it was resent due to “the way our system works and is audited.” He

explained that certified mailings “are logged into a tracking spreadsheet as they are

delivered by the post office to our receptionist” and then “scanned into our document

repository system” while the original copies are distributed to the relevant manager.

Fisher concluded the firm did not receive the order because the firm does not have

an entry in its tracking spreadsheet noting receipt of the order, there is no scan of the

order in the document repository, and the relevant manager did not receive a copy.

Finally, Houston Pipe Line Co also objected to the District’s inclusion of the

screenshot from the United States Postal Service’s website. The company argued

that this document was not properly authenticated and constituted hearsay.

Harris Central Appraisal District replied in support of its jurisdictional plea.

In its reply, the District noted that under the settlement between the appraisal review

board and Houston Pipe Line Co, the board merely agreed to resend the same order

it had previously sent without changing its date (August 29, 2022). Thus, the District

4 argued, resending it did not restart the statutory deadline to appeal. In addition, the

District objected to Fisher’s declaration on the grounds that it was “not based on

personal knowledge, is conclusory, and contains hearsay” in various respects.

As an attachment to its reply, the District included a copy of the Rule 11

settlement agreement between the appraisal review board and Houston Pipe Line

Co. The agreement provided that the board would send its August 29, 2022 written

order to the company, and that the company would then nonsuit the board.

Consistent with their agreement, the board sent the written order to the company on

March 20, 2023, and the company then nonsuited its claim against the board.

The trial court held a hearing on the parties’ competing jurisdictional

positions. It adjourned without ruling, taking their positions under advisement.

Without ruling on any of the evidentiary objections made by the parties, the

trial court later denied the District’s plea to the jurisdiction. The District filed a notice

of interlocutory appeal and a request for a ruling on its objections on the same day.

DISCUSSION

Standard of Review

We review a trial court’s ruling on a plea to the jurisdiction de novo. Tex.

Health & Human Servs. Comm’n v. Pope, 674 S.W.3d 273, 280 (Tex. 2023).

As its name suggests, a plea to the jurisdiction is a procedural device for

challenging a trial court’s subject-matter jurisdiction to hear a suit without reference

5 to the merits of the underlying claims. Bland Indep. Sch. Dist. v. Blue, 34 S.W.3d

547, 553–54 (Tex. 2000). Jurisdictional pleas are of two types, those that challenge

jurisdiction based on the pleadings alone and those that challenge the existence of

jurisdictional facts. Jones v. Turner, 646 S.W.3d 319, 325 (Tex. 2022).

The plea before us challenges the existence of jurisdictional facts. When, as

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Harris Central Appraisal District F/K/A Harris County Appraisal District v. Houston Pipe Line Co LP, Counsel Stack Legal Research, https://law.counselstack.com/opinion/harris-central-appraisal-district-fka-harris-county-appraisal-district-v-texapp-2024.