the Appraisal Review Board of Harris County Appraisal District, and Robert Cunningham, Former Chairman v. O'Connor & Associates, Wolverine Crosby LP, E Pointe Properties I Ltd, Baker-Orr Joint Venture, and J. Frederick Welling

CourtCourt of Appeals of Texas
DecidedAugust 19, 2008
Docket14-07-00354-CV
StatusPublished

This text of the Appraisal Review Board of Harris County Appraisal District, and Robert Cunningham, Former Chairman v. O'Connor & Associates, Wolverine Crosby LP, E Pointe Properties I Ltd, Baker-Orr Joint Venture, and J. Frederick Welling (the Appraisal Review Board of Harris County Appraisal District, and Robert Cunningham, Former Chairman v. O'Connor & Associates, Wolverine Crosby LP, E Pointe Properties I Ltd, Baker-Orr Joint Venture, and J. Frederick Welling) 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
the Appraisal Review Board of Harris County Appraisal District, and Robert Cunningham, Former Chairman v. O'Connor & Associates, Wolverine Crosby LP, E Pointe Properties I Ltd, Baker-Orr Joint Venture, and J. Frederick Welling, (Tex. Ct. App. 2008).

Opinion

Reversed and Rendered and Opinion filed August 19, 2008

Reversed and Rendered and Opinion filed August 19, 2008.

In The

Fourteenth Court of Appeals

____________

NO. 14-07-00354-CV

THE APPRAISAL REVIEW BOARD OF HARRIS COUNTY APPRAISAL DISTRICT AND ROBERT CUNNINGHAM, FORMER CHAIRMAN, Appellants

V.

O=CONNOR & ASSOCIATES, WOLVERINE CROSBY LP, E POINTE PROPERTIES I LTD, BAKER-ORR JOINT VENTURE, AND J. FREDERICK WELLING, Appellees

On Appeal from the 127th District Court

Harris County, Texas

Trial Court Cause No. 2005-47070

O P I N I O N


Appellants, the Appraisal Review Board of Harris County Appraisal District (the Board) and former chairman of the Board Robert Cunningham, appeal the trial court=s denial of their plea to the jurisdiction.  We conclude that because appellees, O=Connor & Associates, Wolverine Crosby Green LP, E Pointe Properties I Ltd., Baker‑Orr Joint Venture, and J. Frederick Welling, failed to exhaust their administrative remedies before filing suit, the district court lacked subject matter jurisdiction over this dispute.  We reverse the trial court=s judgment and render judgment dismissing the case for lack of subject matter jurisdiction. 

I.  Factual and Procedural Background

O=Connor & Associates originally filed suit against Harris County Appraisal District (HCAD), chief appraiser Jim Robinson, the Board, and Cunningham seeking mandamus, injunctive, and declaratory relief.  O=Connor alleged the appellants were violating procedures outlined in the Tax Code for conducting property tax appraisal protest hearings.  O=Connor claimed that, contrary to the Tax Code, the Board was postponing hearings, refusing to consider property owners= evidence, considering evidence that HCAD had not produced to property owners, determining protests in favor of HCAD even when HCAD presented insufficient or no evidence, and issuing only one order to resolve claims contesting both the appraised value and unequal appraisal of the property.

In response, the defendants filed a plea to the jurisdiction asserting that because O=Connor had not exhausted its administrative remedies as required by the Tax Code, the district court lacked subject matter jurisdiction to hear O=Connor=s claims.  The day before the hearing on the defendants= plea to the jurisdiction, O=Connor filed a first amended petition, adding plaintiffs Wolverine Crosby Green LP, E Pointe Properties I Ltd., Baker‑Orr Joint Venture, and J. Frederick Welling (collectively the ATaxpayers@).  The petition also alleged that the plaintiffs had either already filed or would likely file protests of the appraised value of their property for the 2005 tax year and that proper hearings in accordance with chapter 41 of the Tax Code were either untimely held or not held at all. 


The trial court denied the plea to the jurisdiction as to O=Connor=s claims in the original petition only; on appeal, this court dismissed the issue as moot.  See Harris County Appraisal Dist. v. O=Connor & Assocs., No. 14‑06‑00098‑CV, 2006 WL 3072079, at *3 (Tex. App.CHouston [14th Dist.] Oct. 31, 2006, no pet.).[1]  The case returned to the trial court, and after a second hearing on the defendants= plea to the jurisdiction, the trial court granted the plea as to HCAD and Robinson and denied the plea as to the Board and Cunningham.  Now before us on the second appeal in this matter, the Board and Cunningham (collectively the ATaxing Authorities@) argue in two issues that the district court erred in denying their plea to the jurisdiction because the court lacked subject matter jurisdiction and because appellees lack standing. 

II.  Subject Matter Jurisdiction

A plea to the jurisdiction is a dilatory plea seeking to defeat a plaintiff=s claims, regardless of merit, by challenging the district court=s jurisdiction to hear the subject matter of the dispute.  Bland Indep. Sch. Dist. v. Blue, 34 S.W.3d 547, 554 (Tex. 2000).  To prevail, the defendant must show that even if all 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.  Brenham Hous. Auth. v. Davies, 158 S.W.3d 53, 56 (Tex. App.CHouston [14th Dist.] 2005, no pet.).  We review a trial court=s ruling on a plea to the jurisdiction de novo.  See Tex. Dep=t of Parks & Wildlife v. Miranda, 133 S.W.3d 217, 226 (Tex. 2004).  When a plea to the jurisdiction challenges the pleadings, we determine if the pleader has alleged facts affirmatively demonstrating the court=s jurisdiction to hear the cause.  Id.  We construe the pleadings liberally and look to the pleader=s intent.  Id.  


Trial courts are courts of general jurisdiction, and they are presumed to have subject matter jurisdiction unless a contrary showing is made, such as when the legislature bestows exclusive original jurisdiction on an administrative body.  See Tex. Const. art. V, ' 8; Subaru of Am., Inc. v. David McDavid Nissan, Inc., 84 S.W.3d 212, 220 (Tex.

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