Kenedy County Wide School District v. Glenn Hegar, Texas Comptroller of Public Accounts, in His Official and Individual Capacity

Court of Appeals of Texas·Decided March 14, 2025·No. 15-24-00079-CV·Published

Opinion

ACCEPTED 15-24-00079-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 3/14/2025 1:34 PM CAUSE NO. 15-24-00079-CV CHRISTOPHER A. PRINE CLERK FILED IN 15th COURT OF APPEALS AUSTIN, TEXAS IN THE FIFTEENTH COURT OF APPEALS 3/14/2025 1:34:24 PM AUSTIN, TEXAS CHRISTOPHER A. PRINE Clerk

KENEDY COUNTY-WIDE COMMON SCHOOL DISTRICT, Appellant

vs.

GLENN HEGAR, TEXAS COMPTROLLER OF PUBLIC ACCOUNTS, Appellee

Appeal from the 353rd District Court Travis County, Texas Hon. Judge Maya Guerra Gamble, Presiding Judge Trial Court Cause No. D-1-GN-23-002042

APPELLANT’S REPLY BRIEF ____________________________________________________

Judith A. Hargrove State Bar No. 11595050 HARGROVE LAW SEALY, TEXAS 77474 (512) 750-0338 judy@hargrovelawtx.com

COUNSEL FOR APPELLANT TABLE OF CONTENTS

TABLE OF CONTENTS………………………………………………………i

INTRODUCTION……………………………………………..………………1

ARGUMENT………………………………………………………………..…2

I. Reply to Appellee’s Brief II. Reply to ……………………….…..2 Appellee’s Brief II. A.-C.

II. Reply to Appellee’s Brief II. E……………………………………5

CONCLUSION AND PRAYER………………………………………………..6

CERTIFICATE OF WORD COUNT…………………………………….……..7

CERTIFICATE OF SERVICE…………………………………………………..7

i APPELLANT’S REPLY BRIEF

INTRODUCTION

Appellant files this Reply Brief to respond to and clarify the arguments made

by Appellee. Although Appellee’s Brief fails on its own merit to controvert

Appellant’s position, it does confuse the issues by mischaracterizing the relief sought

by Appellant. To be clear, Appellant is not requesting revaluation of the entire

category of all land appraised at productivity value under the provision focused on

by Appellee. It merely requests reduction of its total taxable value to account for

ARB orders reducing productivity values of specific protested properties as found

by the ALJ’s Proposal for Decision. In over-ruling and replacing the ALJ’s

Decision, Appellee violated the statute by focusing only on one provision and

ignoring the others.

Appellee does not dispute Appellant’s authorities concerning the standard of

review. Nor does it dispute Appellant’s argument that the term “taxable value” as

defined in the statute includes “productivity value”. In fact, Appellee explicitly

confirms Appellant’s argument that “taxable value” includes productivity value.

The relevant authorities hold that a reviewing court must reverse and remand the

agency’s order if the appellant’s substantial rights have been prejudiced by an

agency decision that violates a constitutional or statutory provision. Nevertheless,

Appellee insists that it has discretion to act as it wishes even it violates the statute.

1 This position further demonstrates its abuse of discretion in this matter.

ARGUMENT

I. Reply to Appellee’s Brief II. A.-C.

Appellee states that “the dispute on appeal can be reduced to a single legal

question: What value(s) does the language of Texas Government Code section

403.302(b)(4) authorize PTAD to adjust to account for ARB orders? [Appellee’s

Brief at 8]. Although it’s true this question must be answered, it side-steps the

ultimate question of whether Appellee abused its discretion in refusing to comply

with §403.302(b)(4) and (d)(7) by adjusting Appellant’s taxable values for ARB

orders determining productivity value.

Appellee acknowledges that “When an agency decision turns on the

construction of a statute, the question of whether the agency properly construed the

statute is a legal question that an appellate court reviews de novo….the appellate

court’s primary concern is the express statutory language…When an agency

decision turns on the construction of a statute, the question of whether the agency

properly construed the statute is a legal question that an appellate court reviews de

novo. …the appellate court’s primary concern is the express statutory language…

The court applies the plain meaning of the text unless a different meaning is supplied

by legislative definition”. [Appellant’s Brief at 11-12; Appellee’s Brief at 8].

Ignoring these principles, Appellee argues that Texas Government Code 2 section 403.302(b)(4) authorizes the Comptroller to make adjustments only for ARB

orders determining “taxable value,” not “productivity value.” [Appellee’s Brief at

8]. This argument is completely undermined by Appellee’s own analysis of Tex.

Gov. Code §403.302(d)(7) proving that “productivity value” is “taxable value” for

land qualified for productivity appraisal. See Appellee’s Brief at 15-16. Appellee

states:

Tracking the precise language of these two code provisions (Tex. Gov. Code

§403.302(d) and (d)(7)), it is possible to express in mathematical terms the

rules set out, when the property in question is all native pasture land and

where:

x =taxable value,

y =market value,

z =productivity value, and y = z in all cases.

The statutory language can thus be expressed as follows:

x =y - (y- z), which is equivalent to

x -y =-(y- z), or

x -y =-y+ z, or

x =z, or restoring the statutory terms in the place of the variables,

taxable value = productivity value.

In sum, in the case of the native pasture land under review in this case, the

taxable value is equivalent to the productivity value. 3 [Appellee’s Brief at 15-16] [emphasis added]

Appellee’s admission that taxable value of the properties at issue is their

productivity value is a 360º pivot from its earlier position that §403.302(d) defines

taxable value as market value, not productivity value. [RR 39 2-25; SOAH-

004814]. In any case, Tex. Gov. Code §403.302(d) defines “taxable value” “for

purposes “of this section”, which includes §403.302(a) and (b) as well as (d). Thus

by Appellee’s own admission Appellant is correct in arguing that §403.302(b) and

(d) require adjustment to taxable values for ARB orders reducing productivity value

as a matter of law.

Despite this admission, Appellee argues that because §403.302(a) shows that

market value and productivity value are separate and distinct concepts, §403.302(b)

and (d) do not authorize adjustments to taxable values for ARB orders reducing

productivity value. [Appellant’s Br. at 16-18]. Appellee appears to argue that Tex.

Gov. Code §403.302(a) somehow nullifies §403.302(b) and (d). [Appellee’s Brief at

16-18]. This ignores the rules of statutory construction requiring the statute to be

read as a whole and give effect to each provision unless they are in conflict.

Tex. Gov. Code §403.302(a), (b) and (d) are not in conflict; they simply refer

to different requirements of the PVS. Tex. Gov. Code §403.302(a) requires the PVS

to “determine the taxable value of all property and of each category of property in

the district and the productivity value of all land that qualifies for appraisal on the 4 basis of its productive capacity.” On the other hand, §403.302(b) and (d) require

reducing overall taxable values to account for ARB orders reducing those values.

Again, Appellant is not requesting reduction of value for the entire category of all

land appraised at productivity value under Tex. Gov.

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Kenedy County Wide School District v. Glenn Hegar, Texas Comptroller of Public Accounts, in His Official and Individual Capacity, (Tex. Ct. App. 2025).

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Related

§ 403.302
Texas GV § 403.302(d)(7)