Texas Department of Transportation v. Primary Media Group, Inc.

CourtCourt of Appeals of Texas
DecidedAugust 13, 2024
Docket05-22-01273-CV
StatusPublished

This text of Texas Department of Transportation v. Primary Media Group, Inc. (Texas Department of Transportation v. Primary Media Group, Inc.) 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
Texas Department of Transportation v. Primary Media Group, Inc., (Tex. Ct. App. 2024).

Opinion

REVERSE and RENDER and Opinion Filed August 13, 2024

S In The Court of Appeals Fifth District of Texas at Dallas No. 05-22-01273-CV

TEXAS DEPARTMENT OF TRANSPORTATION, Appellant V. PRIMARY MEDIA GROUP, INC., Appellee

On Appeal from the 439th Judicial District Court Rockwall County, Texas Trial Court Cause No. 1-21-1352

MEMORANDUM OPINION Before Justices Goldstein, Garcia, and Miskel Opinion by Justice Goldstein The Texas Department of Transportation (TXDOT or Department) appeals

the trial court’s order denying TXDOT’s motion to dismiss for lack of jurisdiction.

In a single issue, TXDOT argues that, because Primary Media failed to establish a

waiver of sovereign immunity, the trial court should have dismissed the case for

want of jurisdiction. We reverse the trial court’s judgment and render judgment

dismissing Primary Media’s claims for want of jurisdiction. PRIMARY MEDIA’S SECOND AMENDED PETITION

In September 2021, Primary Media filed its original petition asserting breach

of contract claims against TXDOT in connection with Primary Media’s execution of

certain quitclaim deeds and applications to relocate four impacted outdoor

advertising signage. After the filing of TXDOT’s motion to dismiss for lack of

jurisdiction, but prior to the hearing, Primary Media amended its petition twice, the

Second Amended Petition being the live pleading at the time of the hearing (herein

“the petition”). The facts set forth in this section are taken directly from Primary

Media’s petition.

Primary Media is an owner and operator of off-premise, outdoor advertising

signs commonly known as billboards throughout Texas, frequently located adjacent

to interstate highways and major thoroughfares. TXDOT, responsible for widening

and improving state highways, is also the agency charged with regulating and

permitting commercial signs located on the interstate and primary systems.

The petition outlined TXDOT’s treatment of billboards in eminent domain

proceedings as follows:

When acquiring property on which a billboard is located to accommodate a public improvement project, the State treats sign owners differently than other property owners. Acting through the Department, prior to the commencement of formal condemnation proceedings, the State makes an offer to a billboard owner equal to the appraised value of a sign, less a nominal retention value, in exchange for the sign owner’s agreement to remove the impacted billboard.

–2– A billboard owner that chooses to settle with the Department is required, prior to the Special Commissioners’ hearing, to agree upon a value for the impacted sign (ordinarily through a memorandum of agreement or similar exchange of correspondence) and quitclaim its interest in the subject sign to the State of Texas through a nonnegotiable, standard form quitclaim deed prepared and provided by the Department. TxDOT’s standard memoranda of agreement typically include the following form language:

It is important to confirm this agreement in order to avoid any possible misunderstanding as to the details of the purchase or the process by which the Texas Department of Transportation (TxDOT) will make payment. The payment of [the purchase price] as herein agreed will constitute full payment to be made by TxDOT for the property to be conveyed to the State. The consideration recited herein represents a settlement and compromise by all parties as to the value of the property herein conveyed in order to avoid formal eminent domain proceeding and the added expense of litigation.

(emphasis added). The memoranda go on to describe a sign owner’s eligibility for an impacted sign credit:

Under certain circumstances, Rule 21.192 of Title 43 of the Texas Administrative Code allows the owner of a billboard structure to apply for a relocation permit if it is legally erected and maintained and will be within the highway right of way as a result of a highway construction project.

Executing a quitclaim deed and retaining the billboard structure does not guarantee that a relocation permit will be issued. In addition to executing the quitclaim deed and retaining the billboard structure, the owner of the billboard structure must follow and meet the current relocation permitting guidelines found in 43 TAC 21.192, et seq.

The payment of the amount herein stated and the terms provided constitute the only promises, consideration and

–3– conditions of this purchase; and no other promises, consideration and conditions have been signified or implied, save and except the mutual benefits to be derived by you and TxDOT from the signing of this agreement.

The Department’s standard form quitclaim deed provides that the billboard owner will remove the impacted sign after receiving a notice to vacate from the Department. By submitting to this process, a billboard owner waives its right to go through formal condemnation proceedings to obtain an award of just compensation for the loss of the billboard, and waives its right to recover any relocation assistance benefits for the cost to relocate the retained structure.

The State’s settlement procedure for billboards displaced by highway projects is explained in a Department-issued policy titled, “Amended Guidance for Impacted Off-Premise Billboards Affected by Highway Transportation Projects” (the “Guidance”). The Guidance provides that a billboard owner that retains the structure through this settlement process will be eligible for an impacted sign credit under 43 Tex. Admin. Code § 21.192. The same procedure is likewise included in a Department-issued memorandum titled, “Impacted Commercial Signs: What to Expect When Your Sign is Impacted by a TxDOT Construction Project.”

The Department’s regulations applicable to the issuance of impacted sign credits are found in 43 Tex. Admin. Code §§ 21.192, .193, & .195. These sections provide sign owners the ability to relocate a billboard displaced by a highway project using certain relaxed relocation criteria. For example, a relocated sign need only be adjacent to one business, instead of the two businesses required for ordinary new-build signs. 43 Tex. Admin. Code § 21.193(c); cf. 43 Tex. Admin. Code § 21.179(a)(1). Additionally, the various spacing requirements for relocated signs are relaxed, as compared to the spacing requirements for new-build signs. 43 Tex. Admin. Code §21.193(b); cf. 43 Tex. Admin. Code § 21.187. Today, most of the available locations for the construction of new signs have been utilized. As such, a relocation permit that entitles the holder to relax the ordinary regulations for new- build signs is a valuable, private right, which is made all the more valuable due to TxDOT’s required waiver of condemnation rights necessary for the sign owner to receive the TxDOT relocation permit.

–4– After agreeing on a reduced value for an impacted sign (through the execution of a memorandum of agreement or exchange of correspondence with TxDOT) and signing a quitclaim deed, an impacted sign owner will receive a notice to vacate, which specifies the required removal date, and informs the sign owner of the following: “Failure to remove the retained improvements will also result in the loss of eligibility for a relocation permit for the outdoor advertising sign.” After receiving the notice to vacate from the Department, a sign owner is required to remove a sign by the deadline included in the notice. The sign owner is then required to submit TxDOT’s Impacted Sign Credit Application form in order to receive an impacted sign credit.

The Parcel 23 Sign

The petition alleged that Primary Media owned a sign adjacent to IH-35 in

Gainesville, Texas, which was located on property designated by the State as Parcel

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Texas Department of Transportation v. Primary Media Group, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/texas-department-of-transportation-v-primary-media-group-inc-texapp-2024.