Harris County Appraisal District ( Hereinafter the District) v. KMI Yorktown LP

CourtCourt of Appeals of Texas
DecidedApril 29, 2010
Docket01-09-00661-CV
StatusPublished

This text of Harris County Appraisal District ( Hereinafter the District) v. KMI Yorktown LP (Harris County Appraisal District ( Hereinafter the District) v. KMI Yorktown 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 County Appraisal District ( Hereinafter the District) v. KMI Yorktown LP, (Tex. Ct. App. 2010).

Opinion

Opinion issued April 29, 2010.

In The

Court of Appeals

For The

First District of Texas

————————————

NO. 01-09-00661-CV

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Harris County Appraisal District, Appellant

V.

KMI YORKTOWN LP, Appellee

On Appeal from the 151st District Court

Harris County, Texas

Trial Court Case No. 2008-60796

MEMORANDUM OPINION

Harris County Appraisal District [“HCAD”] brings this appeal from the trial court’s order denying its plea to the jurisdiction. In its plea, HCAD contended KMI Yorktown, LLC [“KMI Yorktown”] had no standing to seek judicial review of HCAD’s resolution of an ad valorem tax protest because KMI Yorktown was not the property owner for that tax year. We reverse and render.

BACKGROUND

The property at issue is located on Highway 6 North in Houston. KMI Yorktown sold the property to KM-Timbercreek, LC [“Timbercreek”] by special warranty deed on November 1, 2006. Therefore, according to the record, Timbercreek was the legal owner of the property on January 1, 2008. Nevertheless, KMI Yorktown, but not Timbercreek, filed a notice of protest with HCAD’s Appraisal Review Board concerning the 2008 tax assessment for this property. On August 22, 2008, the chairman of the Appraisal Review Board signed an Order Determining Protest and ordering a reduction in the appraised value of the property. Timbercreek did not pursue a protest as the owner of the property.

KMI Yorktown filed an original petition for judicial review on August 29, 2007, “as the property owner,” challenging the Appraisal Review Board’s determination. KMI Yorktown continued to assert that it owned the property. On May 20, 2009, HCAD filed a plea to the jurisdiction, arguing that (1) KMI Yorktown was not the owner of the property as of January 1, 2008, (2) only the property owner had standing to appeal from the Appraisal Review Board’s order, and, therefore, (3) the trial court lacked subject-matter jurisdiction. HCAD attached a copy of the special warranty deed to its plea.

On May 29, 2009, KMI Yorktown filed a response to HCAD’s plea to the jurisdiction and a motion to substitute Timbercreek as the plaintiff pursuant to Rule 28 of the Texas Rules of Civil Procedure.  On that same date, KMI Yorktown also filed a second amended original petition adding Timbercreek as a plaintiff in the suit for judicial review.  KMI Yorktown’s response also alleged that it was “permitted and authorized to change the name of a party [to the suit for judicial review] pursuant to the provisions of Section 42.21(e) of the Property Tax Code.”

On July 2, 2009, the trial court denied HCAD’s plea to the jurisdiction.  The trial court also denied KMI Yorktown’s Rule 28 motion to substitute Timbercreek as the plaintiff.  Despite a holding from this Court to the contrary, the trial court held that Section 42.21(e) of the Tax Code permits “a different party to be substituted in by amendment” even after the jurisdictional deadline for filing the suit has passed.  In so holding, the trial court stated as follows:

The Court is aware that in Koll Bren Fun [sic] VI, LP v. Harris County Appraisal District, No., 01-07-00321, 2008 WL 525799 (Tex. App.—Houston [1st Dist.], February 28, 2008, pet. denied), the appellate court interprets section 42.21(e) differently, and imposes upon it a further requirement of standing based on the identity of the party who pursued the administrative appeal.  The statute does not talk about this, though.  The Koll Bren court’s interpretation of section 42.21(e) likewise nullifies it.  This Court believes Koll Bren was decided incorrectly, and without deference to the plain working of the statute.

STANDARD OF REVIEW

          Standing is a component of subject-matter jurisdiction that cannot be waived. Bland Indep. Sch. Dist. v. Blue, 34 S.W.3d 547, 553-54 (Tex. 2000).  If a party has no standing, a trial court has no subject-matter jurisdiction to hear the case. Id. If a jurisdiction defect cannot be cured by an amendment, a party may file a plea to the jurisdiction, and, if the trial court finds the plea meritorious, it may grant it without allowing the plaintiff an opportunity to amend.  See County of Cameron v. Brown, 80 S.W.3d 549, 555 (Tex.  2002).  A defendant may prevail on a plea to the jurisdiction by demonstrating that, even if all of the plaintiff’s pleaded allegations are true, an incurable jurisdictional defect remains on the face of the pleadings that deprives the trial court of subject-matter jurisdiction. Harris County Appraisal Dist. v. O’Connor & Assocs., 267 S.W.3d 413, 416 (Tex. App.—Houston [14th Dist.] 2008, no pet.).  A trial court decides a plea to the jurisdiction by reviewing the pleadings as well as any evidence relevant to the jurisdictional inquiry.  Blue, 34 S.W. 3d at 555.  We review a trial court’s ruling on a plea to the jurisdiction de novo, construing the pleadings liberally in favor of the plaintiff while considering the pleader’s intent.  Tex. Dep’t of Parks & Wildlife v. Miranda, 133 S.W.3d 217, 226, 228 (Tex. 2004).   In a review of a plea to the jurisdiction, we cannot examine the merits of the case. See Houston Indep. Sch. Dist. v. 1615 Corp., 217 S.W.3d 631, 635 (Tex. App.—Houston [14th Dist.] 2006, pet. denied) (op. on reh’g).

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Related

Texas Department of Parks & Wildlife v. Miranda
133 S.W.3d 217 (Texas Supreme Court, 2004)
Chilkewitz v. Hyson
22 S.W.3d 825 (Texas Supreme Court, 1999)
Bland Independent School District v. Blue
34 S.W.3d 547 (Texas Supreme Court, 2000)
KM-Timbercreek, LLC v. Harris County Appraisal District
312 S.W.3d 722 (Court of Appeals of Texas, 2009)
Houston Independent School District v. 1615 Corp.
217 S.W.3d 631 (Court of Appeals of Texas, 2007)
Dean v. Lafayette Place (Section One) Council of Co-Owners, Inc.
999 S.W.2d 814 (Court of Appeals of Texas, 1999)
Sixth RMA Partners, L.P. v. Sibley
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Seidler v. Morgan
277 S.W.3d 549 (Court of Appeals of Texas, 2009)
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311 S.W.3d 649 (Court of Appeals of Texas, 2010)

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Harris County Appraisal District ( Hereinafter the District) v. KMI Yorktown LP, Counsel Stack Legal Research, https://law.counselstack.com/opinion/harris-county-appraisal-district-hereinafter-the-d-texapp-2010.