the City of Houston v. Gerald A. P. Boyle

CourtCourt of Appeals of Texas
DecidedJuly 8, 2004
Docket01-03-00759-CV
StatusPublished

This text of the City of Houston v. Gerald A. P. Boyle (the City of Houston v. Gerald A. P. Boyle) 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 City of Houston v. Gerald A. P. Boyle, (Tex. Ct. App. 2004).

Opinion

Opinion issued July 8, 2004 



In The

Court of Appeals

For The

First District of Texas





NO. 01-03-00016-CV

NO. 01-03-00759-CV





CITY OF HOUSTON, Appellant


V.


GERALD A.P. BOYLE, Appellee





On Appeal from the 55th District Court

Harris County, Texas

Trial Court Cause No. 2002-46152





O P I N I O N

          Appellant, the City of Houston (the City), defendant in the trial court, brings these accelerated, interlocutory appeals to challenge two orders by which the trial court refused to grant the City’s pleas to the jurisdiction for the claims of appellee, Gerald A.P. Boyle. In Cause No. 01-03-00016-CV, the City brings a single issue to challenge the trial court’s first order on the grounds that Boyle did not, despite opportunity to amend his pleadings, allege facts sufficient to confer jurisdiction. In Cause No. 01-03-00759-CV, which the City pursued after the trial court denied the City’s plea a second time, the City brings two issues. The first issue challenges the trial court’s holding that Boyle’s property-damage claim for nonnegligent nuisance is not a claim for inverse condemnation. The second issue addresses the trial court’s decision to abate the trial-court proceedings to permit Boyle to replead to exclude his inverse-condemnation claim; the City contends that the trial court erred by not dismissing that claim for want of jurisdiction. We address these appeals together and reverse and render.


Underlying Facts and Procedural Background

          Boyle owns property in the Forest Cove Country Club Estates (Forest Cove) subdivision in Kingwood, Harris County. After annexing property in this area in 1996, the City began maintaining the drainage ditches in the area—a function previously performed by Harris County. In addition, the City approved plans and issued permits for construction of a shopping center and apartment complex near the Forest Cove subdivision.

          When Boyle’s property flooded during tropical storm Allison and again in fall 2001 and fall 2002, Boyle sued the City and others (not parties to this appeal) for damage to and loss of his property. Factually, Boyle’s pleadings alleged that the City did not maintain the drainage ditches properly and that the City should not have issued building permits for construction near the Forest Cove subdivision because the new construction placed an excessive burden on the drainage ditches in the subdivision. Boyle’s pleadings sought damages by imposing liability on the City under the following legal theories: inverse condemnation and nonnegligent nuisance, pursuant to Article I, section 17 of the Texas Constitution; and recovery authorized by the Tort Claims Act (TCA).

          The City filed special exceptions to the pleadings, which the trial court denied, and then filed a plea to the jurisdiction to challenge the trial court’s subject-matter jurisdiction to consider Boyle’s claims, which the trial court also denied. The City perfected an appeal to this Court to challenge that ruling, under Cause No. 01-03-00016-CV. While that cause was pending in this Court, our sister court issued its opinion in Taub v. Aquila Southwest Pipeline Corp., 93 S.W.3d 451 (Tex. App.—Houston [14th Dist.] 2002, no pet.). In its second plea to the jurisdiction, the City relied on Taub to argue, as Taub held, that the Harris County Civil Courts at Law had exclusive jurisdiction over Boyle’s article I, section 17 claims for inverse condemnation and nonnegligent nuisance pursuant to section 25.1032(c) of the Government Code. See Taub, 93 S.W.3d at 458-59.

          The trial court’s order denying the City’s plea acknowledged that the trial court

lacked jurisdiction over Boyle’s inverse condemnation claim. In the same order, the trial court abated the suit until Boyle amended his pleadings to remove that claim. Because the order again denied the City’s plea, we may infer that the trial court concluded that it retained jurisdiction over Boyle’s remaining claims. On the parties’ joint motion for clarification of that order, the trial court signed an amended order. This order again denied the City’s plea and ordered all proceedings abated until Boyle amended his pleadings to exclude his claim for inverse condemnation, but held, in addition, that Boyle’s non-negligent nuisance claim was not an article I, section 17 claim “within the meaning of section 25.1032(c) of the Texas Government Code” and thus implicitly held that the trial court retained jurisdiction over that claim.

Plea to the Jurisdiction

          A trial court must have subject-matter jurisdiction to adjudicate the subject matter of a cause of action. Tex. Dep’t of Parks & Wildlife v. Miranda, No. 01-0619, 47 Tex. Sup. Ct. J. 386, 390-91 (April 2, 2004). The burden is on the plaintiff to plead facts that affirmatively demonstrate subject-matter jurisdiction. Tex. Ass’n of Bus. v. Tex. Air Control Bd., 852 S.W.2d 440, 446 (Tex. 1993). Subject-matter jurisdiction may be challenged by a plea to the jurisdiction authorized by rule 85. See Miranda, 47 Tex. Sup. Ct. J. at 390; Tex. Dep’t of Transp. v. Jones, 8 S.W.3d 636, 638-39 (Tex. 1999); Tex. R. Civ. P. 85.

          Whether the plaintiff has alleged facts that demonstrate subject-matter jurisdiction is a question of law. Miranda, 47 Tex. Sup. Ct. J. at 390. Therefore, we review the trial court’s granting or denying the plea de novo. Mayhew v. Town of Sunnyvale, 964 S.W.2d 922, 928 (Tex. 1998). In asserting a plea to the jurisdiction, a party contends that an incurable jurisdictional defect precludes the court’s hearing the case on the merits, even if all allegations in the pleadings are true. Bland Indep. Sch. Dist. v. Blue, 34 S.W.3d 547, 554 (Tex. 2000); City of Houston v. Northwood Mun. Dist. No. 1, 73 S.W.3d 304, 307 (Tex. App.—Houston [1st Dist.] 2001, no pet.).

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