RRB Land Investments LTD Commonly Known by as Cypresswood Venture I Ltd v. Harris County Appraisal District and the Appraisal Review Board of Harris County Appraisal District

CourtCourt of Appeals of Texas
DecidedApril 29, 2010
Docket01-09-00519-CV
StatusPublished

This text of RRB Land Investments LTD Commonly Known by as Cypresswood Venture I Ltd v. Harris County Appraisal District and the Appraisal Review Board of Harris County Appraisal District (RRB Land Investments LTD Commonly Known by as Cypresswood Venture I Ltd v. Harris County Appraisal District and the Appraisal Review Board of 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.

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RRB Land Investments LTD Commonly Known by as Cypresswood Venture I Ltd v. Harris County Appraisal District and the Appraisal Review Board of Harris County Appraisal District, (Tex. Ct. App. 2010).

Opinion

Opinion issued April 29, 2010.

In The

Court of Appeals

For The

First District of Texas

————————————

NO. 01-09-00519-CV

———————————

RRB LAND INVESTMENTS, LTD. AND CYPRESSwood VENTURE I, LTD., Appellants

V.

harris county appraisal district, Appellee

On Appeal from the 281st District Court

Harris County, Texas

Trial Court Case No. 2008-55258

MEMORANDUM OPINION

Appellants, RRB Land Investments, Ltd.  [“RRB”] and Cypress Venture I, Ltd. [“Cypresswood”] bring this appeal from the trial court’s order granting Harris County Appraisal District’s [“HCAD’s”] plea to the jurisdiction. In its plea, HCAD contended the Cypresswood had no standing to seek judicial review of HCAD’s resolution of an ad valorem tax protest because it was not the property owners for that tax year. We affirm.

BACKGROUND

Cypresswood sold the property located at 6401 Cypresswood Drive in Spring, Texas to RRB by special warranty deed dated April 24, 2006. Therefore, according to the record, RRB was the legal owner of the property on January 1, 2008. Nevertheless, Cypresswood, but not RBB, filed a notice of protest with HCAD’s Appraisal Review Board concerning the 2008 tax assessment for this property. On July 25, 2008, the chairman of the Appraisal Review Board signed an Order Determining Protest, ordering a reduction in the appraised value of the property, which was delivered to Cypresswood on August 1, 2008. RRB did not pursue a protest as the owner of the property.

Cypresswood filed an original petition for judicial review on September 11, 2008, “as the property owners,” challenging the Appraisal Review Board’s determination.  Cypresswood continued to assert that it owned the property. On April 2, 2009, HCAD filed a plea to the jurisdiction, arguing that (1) Cypresswood was not the owner of the properties of January 1, 2008, (2) only the property owner had standing to appeal from the Review Board’s order, and, therefore, (3) the trial court lacked subject-matter jurisdiction. HCAD attached copies of the general warranty deeds to its plea.

On April 3, 2009, Cypresswood filed a motion to substitute RRB as the plaintiff pursuant to Rule 28 of the Texas Rules of Civil Procedure.  On that same date, Cypresswood also filed a first amended original petition adding RRB as a plaintiff in the suit for judicial review.  Cypresswood argued in its motion to substitute RBB 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 May 11, 2009, the trial court granted HCAD’s plea to the jurisdiction.  This appeal followed. 

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 jurisdictional 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).

JURISDICTION OVER SUIT FOR JUDICIAL REVIEW

In a single issue, the appellants assert that the trial court erred in granting HCAD’s plea to the jurisdiction. HCAD responds that the trial court lacked jurisdiction because, although Cypresswood timely filed a petition for judicial review in the name of “as the property owners and the property owners” following the Appraisal Review Board’s order, RRB, not Cypresswood was the property owner at the relevant time. HCAD also argues that Cypresswood could not amend its petition to include RRB pursuant to section 42.21(e)(1) of the Tax Code and Texas Rule of Civil Procedure 28.

Standing

This Court and the Fourteenth Court of Appeals have repeatedly addressed these jurisdictional issues. See Woodway Drive, LLC v. Harris County Appraisal Dist., No.

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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)
Sixth RMA Partners, L.P. v. Sibley
111 S.W.3d 46 (Texas Supreme Court, 2003)
Seidler v. Morgan
277 S.W.3d 549 (Court of Appeals of Texas, 2009)
County of Cameron v. Brown
80 S.W.3d 549 (Texas Supreme Court, 2002)
Woodway Drive LLC v. Harris County Appraisal District
311 S.W.3d 649 (Court of Appeals of Texas, 2010)

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RRB Land Investments LTD Commonly Known by as Cypresswood Venture I Ltd v. Harris County Appraisal District and the Appraisal Review Board of Harris County Appraisal District, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rrb-land-investments-ltd-commonly-known-by-as-cypresswood-venture-i-ltd-v-texapp-2010.