Hotel Corporation International v. Harris County Appraisal District

CourtCourt of Appeals of Texas
DecidedJune 3, 2010
Docket14-09-00006-CV
StatusPublished

This text of Hotel Corporation International v. Harris County Appraisal District (Hotel Corporation International v. Harris County Appraisal District) 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
Hotel Corporation International v. Harris County Appraisal District, (Tex. Ct. App. 2010).

Opinion

Affirmed and Memorandum Opinion filed June 3, 2010.

In The

Fourteenth Court of Appeals

___________________

NO. 14-09-00006-CV

Hotel Corporation International, Appellant

V.

Harris County Appraisal District, Appellee

On Appeal from the 152nd District Court

Harris County, Texas

Trial Court Cause No. 2007-76096

MEMORANDUM OPINION

In this case arising from 2006 tax appraisals of real property and business personal property, appellant Hotel Corporation International (“Hotel Corp.”) appeals from the district court’s order dismissing its suit against appellee Harris County Appraisal District (“HCAD”).  We conclude that Hotel Corp.’s failure to pay property taxes before the statutory delinquency date resulted in a forfeiture of its right to a final determination of its appeals.  We therefore affirm.

I.  Background

The underlying tax dispute involves both real property and business personal property.  The real property is known as the Days Inn Greenspoint and is located at 12500 North Freeway, Houston, Texas.  The taxable business personal property, also owned by Hotel Corp., is located at the same address. 

In the 2006 tax year, HCAD appraised the value of the real property at $3,403,000, and valued the business personal property at $166,646.  Hotel Corp. filed protests to both valuations but then failed to appear at scheduled hearings.  The record does not reflect Hotel Corp. paid any portion of its property taxes by February 1, 2007, the “delinquency date” for the payment of 2006 taxes.

Instead, appellant requested “correction” of both appraisals.  As to the real property, however, Hotel Corp. again failed to show for the hearing on its request for a correction.  It did appear at the correction hearing as to the business personal property, and HCAD in fact reduced the appraised value to $88,000, roughly half of the original assessment.

Hotel Corp. sued HCAD in district court, requesting (1) a declaration the real property be valued at not more than $1,833,354 and the business personal property, not more than $40,000, (2) an order compelling administrative hearings, and (3) damages and attorney’s fees.[1]  HCAD responded with a general denial and subsequently filed a plea to the jurisdiction and motion for dismissal.  It argued Hotel Corp. was “not entitled to any of the relief sought because it (a) failed to exhaust the administrative remedies, (b) failed to comply with timely tax payment requirements, and (c) prematurely filed this suit as it pertains to the correction order on the business personal property.”  The district court granted HCAD’s plea and motion and dismissed the cause against HCAD.

II. Discussion

In its sole issue on appeal, Hotel Corp. contends the trial court had jurisdiction under section 41.45(f) of the Texas Property Code because appellant timely protested the appraisals and requested correction of the estimated values.  HCAD responds with the three arguments it presented in its plea and motion in the trial court, relying first on its argument that Hotel Corp. forfeited all its claims because it did not pay any taxes on the real property or business personal property before the delinquency date.

After setting forth the standard of review, we consider the ramifications of Hotel Corp.’s not having paid any property taxes before the delinquency date.  We then consider Hotel Corp.’s argument that, under section 41.45(f), it was entitled to bring suit in district court to obtain an order compelling the appraisal board to hold hearings.

A.  Standard of Review

This court reviews a trial court’s ruling on a plea to the jurisdiction de novo.  Tex. Dep’t of Parks & Wildlife v. Miranda, 133 S.W.3d 217, 228 (Tex. 2004).  A defendant’s jurisdictional plea may challenge either the plaintiff’s pleadings or the existence of jurisdictional facts.  See id. at 226–28.  When, as here, the defendant challenges the existence of jurisdictional facts, the court must consider the relevant evidence submitted by the parties.  See id. at 227.  If that evidence raises a fact issue as to jurisdiction, the court must deny the defendant’s plea because the trier of fact must resolve the issue.  See id. at 227–28.  However, if the relevant evidence is undisputed or fails to present a jurisdictional fact issue, the court should grant the plea as a matter of law.  Id. at 228.  In reviewing the evidence, this court must assume the truth of all evidence favoring the nonmovant, in this case, Hotel Corp.  See id.

B.  Application of the Texas Property Tax Code

The Property Tax Code provides detailed administrative procedures for property owners who contest their property taxes.  Cameron Appraisal Dist. v. Rourk, 194 S.W.3d 501, 502 (Tex. 2006).  These remedial procedures are, with a few exceptions, exclusive and jurisdictional.  See id.; see also Tex. Tax Code Ann. § 42.09(a) (Vernon 2008).

Property Tax Code section 42.01 grants property owners a right to judicial review of an appraisal review board’s decisions.  That section provides in relevant part:  “A property owner is entitled to appeal . . . an order of the appraisal review board determining:  (A) a protest by the property owner as provided by Subchapter C of Chapter 41; or (B) a determination of an appraisal review board on a motion filed under Section 25.25.”  Tex. Tax Code Ann. § 42.01(1) (Vernon 2008).[2]  Thus, authorization for judicial review of the appraisal board’s decisions on both protests and correction motions is found in chapter 42.  To be entitled to, and to exercise, the right of appeal from determinations of valuation, property owners must follow the procedures prescribed by the Property Tax Code because those procedures are the exclusive means for judicial review.  Ferguson v. Chillicothe Indep. Sch. Dist., 798 S.W.2d 395, 397 (Tex.

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Related

Texas Department of Parks & Wildlife v. Miranda
133 S.W.3d 217 (Texas Supreme Court, 2004)
Cameron Appraisal District v. Rourk
194 S.W.3d 501 (Texas Supreme Court, 2006)
Ferguson v. Chillicothe Independent School District
798 S.W.2d 395 (Court of Appeals of Texas, 1990)

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Bluebook (online)
Hotel Corporation International v. Harris County Appraisal District, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hotel-corporation-international-v-harris-county-ap-texapp-2010.