J-W Power Company (Cross-Appellee) v. Frio County Appraisal District (Cross-Appellant)

Texas Court of Appeals, 4th District (San Antonio)·Decided August 26, 2026·No. 04-21-00564-CV·Published

Opinion

Fourth Court of Appeals

San Antonio, Texas

MEMORANDUM OPINION

No. 04-21-00564-CV

J-W POWER COMPANY,

Appellant

v.

FRIO COUNTY APPRAISAL DISTRICT, Appellee

From the 81st Judicial District Court, Frio County, Texas Trial Court No. 19-07-00221-CVF Honorable Russell Wilson, Judge Presiding

Opinion by: H. Todd McCray, Justice

Sitting: Lori I. Valenzuela, Justice Lori Massey Brissette, Justice H. Todd McCray, Justice

Delivered and Filed: August 26, 2026 AFFIRMED IN PART AND REVERSED AND RENDERED IN PART J-W Power Company (“J-W Power”) sued the Frio County Appraisal District (“FCAD”)

to remove its natural gas compressors from the county’s appraisal rolls for tax years 2013–2016 and to reimburse it for excess taxes paid, with interest and attorney’s fees. Both parties filed motions for summary judgment. In a final judgment, the trial court granted FCAD’s motion for summary judgment in part and J-W Power’s motion for summary judgment in part, ordering FCAD

to remove specific compressors from the tax rolls for certain years. Both parties appealed from this judgment.

In a prior opinion in this appeal, we held that J-W Power’s motion to correct the rolls was barred by res judicata. See J-W Power Co. v. Frio Cnty. Appraisal Dist. (Frio Cnty. I), 692 S.W.3d 614 (Tex. App.—San Antonio 2023), rev’d, 691 S.W.3d 923 (Tex. 2024) (Frio Cnty. II). The Texas Supreme Court reversed our prior disposition and remanded the case for us to consider issues we did not previously reach. Having now considered all dispositive issues, we determine that FCAD was entitled to a take-nothing judgment on J-W’s Power’s claims as to all compressors for all tax years, save its claims to remove compressor numbers 3678 and 3681 from the FCAD appraisal rolls for tax year 2016. Only those specific compressors in that year were subject to multiple appraisals based on the summary judgment evidence. Therefore, we affirm the trial court’s judgment to the extent that it accords with our holding and reverse and render judgment to the limited extent the trial court’s judgment diverges from our holding.

BACKGROUND

A dealer’s heavy equipment inventory (“DHEI”) consists of the heavy equipment a dealer owns and may lease to its customers. See TEX. TAX CODE ANN. § 23.1241(a)(2). J-W Power sells and leases self-powered natural gas compressors which the parties agree qualifies as DHEI. It stores and maintains its compressors at storage yards located in several Texas counties, including Jim Wells County. From 2013–2016, some of its compressors stored at the Jim Wells County yard were leased for service in nearby counties, including Frio County.

In 2011 and earlier, counties assessed taxes on individual equipment that was physically located in their jurisdictions as business personal property. See TEX. TAX CODE ANN. § 22.01; EXLP Leasing, LLC v. Galveston Cent. Appraisal Dist., 554 S.W.3d 572, 574 (Tex. 2018).

However, in 2011, the legislature amended the Texas Tax Code to provide that all equipment, including leased equipment, which met the definition of DHEI, should be appraised and taxed collectively as inventory. See Act of May 21, 2011, 82d Leg., R.S., ch. 322, §§ 1–3, 2011 Tex. Gen. Laws 938, 938–39 (codified at TEX. TAX CODE ANN. §§ 23.1241, .1242); J-W Power Co. v. Duval Cnty. Appraisal Dist., No. 04-21-00172-CV, 2022 WL 789345, at *1 (Tex. App.—San Antonio Mar. 16, 2022, no pet.) (mem. op.). Leased DHEI equipment was appraised and taxed by the county where it was originally stored and maintained as inventory (the “Inventory County”), rather than the county where it was physically located during the lease. See TEX. TAX CODE ANN. §§ 23.1241–42. Additionally, the market value of DHEI inventory would be determined by the previous calendar year’s annual lease income generated from the inventory, rather than from the value of individual compressors. TEX. TAX CODE ANN. § 23.1241(c); see EXLP Leasing, 554 S.W.3d at 583. Texas law requires that annual declarations showing the market value of the inventory be filed with the Inventory County. TEX. TAX CODE ANN. § 23.1241(f). Additionally, the owner of leased equipment is required to file monthly statements with the Inventory County and “deposit with the collector an amount equal to the total of unit property tax assigned to all items of heavy equipment sold, leased, or rented from the dealer’s heavy equipment inventor in the preceding month to which a unity property tax was assigned.” TEX. TAX CODE ANN. § 23.1242(b). 1

1 The version of section 23.1242 in effect during the relevant time period required monthly reporting to the relevant appraisal district. TEX. TAX CODE ANN. § 23.1242 (2025). However, in the 2025 legislative session, the law was updated to mandate quarterly reporting of leases and sales. Act of May 23, 2025, 89th Leg., R.S., ch. 439, § 1, Tex. Gen. Laws 6073 (current version at TEX. TAX CODE § 23.1242).

Despite the changes to the Tax Code, for appraisals from tax years 2013–2016, 2 FCAD continued taxing J-W Power’s compressors leased to locations within Frio County, as business personal property under the default market-value rule, by looking at the value of each compressor. See TEX. TAX CODE ANN. § 22.01. While others litigated the constitutionality of the Tax Code changes, see, e.g., EXLP Leasing, 554 S.W.3d at 574, J-W Power paid the taxes FCAD assessed on its compressors. In addition to paying the property tax assessed by FCAD, J-W Power attempted to comply with the statute and filed some monthly statements and annual declarations for compressors leased out of the Jim Wells County yard to the Jim Wells County Appraisal District (“CAD”).

Before paying the assessed taxes to Frio County, J-W Power timely protested its FCAD appraisals each year under the mechanism provided in Chapter 41 of the Tax Code. See TEX. TAX CODE ANN. § 41.41(a) (providing broad authority to property owners to protest a property’s appraised value or “any other action of the chief appraiser, appraisal district, or appraisal review board that applies to and adversely affects the property owner”). J-W Power argued that FCAD was improperly taxing the DHEI compressors located in Frio County as business personal property under Tax Code section 22.01 despite the changes in the law requiring the Inventory County to tax the compressors. Each year’s protest was reviewed by the Frio County Appraisal Review Board (“ARB”), but each protest was denied. J-W Power did not seek judicial review of the Chapter 41 protests during the 2013–2016 tax years.

Following the Texas Supreme Court’s decision in EXLP Leasing, upholding the constitutionality of the 2011 legislative changes to the DHEI taxing method, J-W Power filed

2 A tax year coincides with a calendar year, but we specify tax years throughout this opinion to avoid confusion because the changes to the Tax Code required DHEI to be appraised based on the previous calendar year’s income generated. See TEX. TAX CODE ANN. § 23.1241(b).

motions to correct the appraisal rolls for tax years 2013–2016 under the more limited relief found in Chapter 25 of the Tax Code with the Frio ARB. See TEX. TAX CODE ANN. § 25.25(c); EXLP Leasing, 554 S.W.3d at 583, 586. During this protest, J-W Power argued that its compressors leased to locations within Frio County should be removed from FCAD’s rolls because they had been subject to multiple appraisals in both Frio County and Jim Wells County (the Inventory County), and because the compressors were improperly classified as business personal property by the FCAD. The Frio County ARB denied J-W Power’s motions to correct the rolls. Unlike its prior Chapter 41 protests, J-W Power sought judicial review and sued FCAD.

In the district court, FCAD moved for summary judgment and raised five issues. It argued that:

(1) Section 25.25 of the Texas Property Tax Code is not the appropriate vehicle to challenge situs or appraisal categorization;

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J-W Power Company (Cross-Appellee) v. Frio County Appraisal District (Cross-Appellant), (Tex. Ct. App. 2026).

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