Matt Gilbert v. Houston Independent School District

CourtCourt of Appeals of Texas
DecidedSeptember 24, 2009
Docket01-06-00159-CV
StatusPublished

This text of Matt Gilbert v. Houston Independent School District (Matt Gilbert v. Houston Independent School 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
Matt Gilbert v. Houston Independent School District, (Tex. Ct. App. 2009).

Opinion

Opinion issued September 24, 2009




In The

Court of Appeals

For The

First District of Texas

____________


NO. 01-06-00159-CV


JAMES M. GILBERT A/K/A MATT GILBERT, Appellant


V.


HOUSTON INDEPENDENT SCHOOL DISTRICT, CITY OF HOUSTON, HARRIS COUNTY, AND HOUSTON COMMUNITY COLLEGE SYSTEM, Appellees





On Appeal from the 270th District Court

Harris County, Texas

Trial Court Cause No. 2001-65202




MEMORANDUM OPINION


          James M. (Matt) Gilbert, a pro se litigant, appeals the trial court’s judgment imposing a tax lien against his house and granting permission for the taxing authorities to sell the property to satisfy the tax delinquency.

          Matt brings eight issues. In five issues, Matt complains about procedural issues relating to his sister’s disclaimer of interest in the property. Matt also complains that he did not receive notice of the trial date, that the taxing authorities’ trial attorney commented negatively to him, and that the valuation process was unfair as to his property.

          We affirm.

Background

          Appellee Houston Independent School District filed this lawsuit to recover delinquent property taxes dating from 1987. Other taxing authorities, including appellees Harris County, the City of Houston, and the Houston Community College System, later joined the suit as additional plaintiffs.

          The property subject to the tax liability at issue is an improved lot in Harris County that had been owned by John E. Gilbert and Mary V. Gilbert. Both John and Mary died intestate. The taxing authorities filed this in rem suit in 2001, and the court appointed an attorney ad litem to identify John and Mary’s heirs. Five heirs were identified, including Matt and his sister Mary Gilbert McAdams. The heirs were joined as defendants and served with process. Only Matt, who had lived since 1985 in a house on the property at issue, claimed an interest in the property.

          During the time Matt lived in the house, property taxes went unpaid for significant periods of time. At the time of trial, delinquent taxes were owed:

                  to the Houston Independent School District for tax years 1990 through 2004;


                  to Harris County for tax years 1988 through 2004;


                  to the City of Houston for tax years 1987 through 2004; and


                  to the Houston Community College System for tax years 1987 through 2004.


Although Matt filed a written answer and appeared in court, he did not appear for the trial on January 24, 2006. A notice of trial setting for that date includes Matt on the certificate of service, but the U.S. Postal Service returned the service copy to the taxing authorities’ counsel, marked “unclaimed.”

          After a bench trial to a tax master, the trial court rendered judgment in favor of the taxing authorities, permitting them to sell the house to satisfy their tax liens and charging Matt with interest, fees, and court costs. Matt appeals.

Pro Se Representation

          Matt represented himself in the trial court, and he also appears before this Court pro se. Although we liberally construe pro se pleadings and briefs, we nonetheless require pro se litigants to comply with applicable laws and rules of procedure. See Wheeler v. Green, 157 S.W.3d 439, 444 (Tex. 2005) (“pro se litigants are not exempt from the rules of procedure”); Mansfield State Bank v. Cohn, 573 S.W.2d 181, 184–85 (Tex. 1978). “Having two sets of rules—a strict set for attorneys and a lenient set for pro se parties—might encourage litigants to discard their valuable right to the advice and assistance of counsel.” Wheeler, 157 S.W.3d at 444. “Litigants who represent themselves must comply with the applicable procedural rules, or else they would be given an unfair advantage over litigants represented by counsel.” Mansfield State Bank, 573 S.W.2d at 185; see also Stein v. Lewisville Indep. Sch. Dist., 481 S.W.2d 436, 439 (Tex. Civ. App.—Fort Worth 1972, writ ref’d n.r.e.) (holding that pro se defendants in tax foreclosure are bound by rules of procedure). Construing his briefing liberally, the issues Matt presents lack substantive merit.

Competency of Mary Gilbert McAdams

          In five issues, Matt argues that his sister Mary McAdams is legally incompetent and that she was not properly represented by the attorney ad litem, who was appointed to identify the then-unknown heirs of John and Mary Gilbert. The issues lack merit because Matt lacks standing to assert these issues for his own benefit, and he lacks the legal capacity to assert these issues on behalf of his sister.

Standing

          Generally, only parties of record have standing to appeal. See Cont’l Cas. Co. v. Huizar, 740 S.W.2d 429, 430 (Tex. 1987). Standing requires that the parties have a real controversy which can actually be determined by the relief sought. Tex. Ass’n of Bus. v. Tex. Air Control Bd., 852 S.W.2d 440, 446 (Tex. 1993). In other words, a person has standing to appeal when he is personally aggrieved by the alleged wrong. Nootsie, Ltd. v. Williamson County Appraisal Dist., 925 S.W.2d 659

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Matt Gilbert v. Houston Independent School District, Counsel Stack Legal Research, https://law.counselstack.com/opinion/matt-gilbert-v-houston-independent-school-district-texapp-2009.