Westview Drive Investments v. Harris Central Appraisal District F/K/A Harris County Appraisal District

CourtCourt of Appeals of Texas
DecidedNovember 25, 2025
Docket01-25-00205-CV
StatusPublished

This text of Westview Drive Investments v. Harris Central Appraisal District F/K/A Harris County Appraisal District (Westview Drive Investments v. Harris Central Appraisal District F/K/A 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.

Bluebook
Westview Drive Investments v. Harris Central Appraisal District F/K/A Harris County Appraisal District, (Tex. Ct. App. 2025).

Opinion

Opinion issued November 25, 2025

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-25-00205-CV ——————————— WESTVIEW DRIVE INVESTMENTS, Appellant V. HARRIS CENTRAL APPRAISAL DISTRICT F/K/A HARRIS COUNTY APPRAISAL DISTRICT, Appellee

On Appeal from the 157th District Court Harris County, Texas Trial Court Case No. 2024-50252

MEMORANDUM OPINION

The underlying case involves a dispute between Westview Drive Investments,

LLC (WDI) and Harris Central Appraisal District (HCAD)1 over the 2024 appraised

1 Harris Central Appraisal District was formerly known as Harris County Appraisal District. value of WDI’s real property for ad valorem tax purposes. WDI seeks permission

in this Court to bring an interlocutory appeal of the trial court’s amended order

denying its motion for summary judgment. See TEX. CIV. PRAC. & REM. CODE

§ 51.014(d), (f); TEX. R. APP. P. 28.3(a).

In the amended order, the trial court certified one question for permissive

appeal: “whether TEX. TAX CODE § 23.231 limits the appraised value of WDI’s

property . . . for tax year 2024, to no more than 20 percent above the appraised value

of the property in tax year 2023.” Because we conclude that the issue presented by

this question is not ripe for review, we deny WDI’s petition for permissive appeal.

Background

We begin with an overview of Tax Code Section 23.231 because it aids in

understanding the procedural history of the case.

A. Circuit Breaker Limitation

Tax Code Section 23.231 (the Circuit Breaker Limitation2) was enacted in

2023.3 The statute became effective on January 1, 2024.4

2 The title of Section 23.231 is “Circuit Breaker Limitation on Appraised Value of Real Property Other than Residence Homestead.” TEX. TAX CODE § 23.231. 3 See Act of July 13, 2023, 88th Leg., 2nd C.S., ch. 1, § 4.03, sec. 23.231, Tex. Sess. Law Serv. 4700, 4706–08. 4 See Act of July 13, 2023, 88th Leg., 2nd C.S., ch. 1, §§ 8.01, 8.05, Tex. Sess. Law Serv. 4700, 4721. 2 The Circuit Breaker Limitation applies to real property “with an appraised

value of not more than the amount determined under Subsection (j) for the tax year

in which the property first qualifies for the circuit breaker limitation.” TEX. TAX

CODE § 23.231(b). For the 2024 tax year, that amount is $5 million or less.5 Id.

§ 23.231(j).

When a property qualifies, Subsection (d) limits the amount that an appraisal

office can increase the appraised value of the property:

(d) Notwithstanding the requirements of Section 25.186 and regardless of whether the appraisal office has appraised the property and determined the market value of the property for the tax year, an appraisal office may increase the appraised value of real property to which this section applies for a tax year to an amount not to exceed the lesser of:

(1) the market value of the property for the most recent tax year that the market value was determined by the appraisal office; or

(2) the sum of:

(A) 20 percent of the appraised value of the property for the preceding tax year;

(B) the appraised value of the property for the preceding tax year; and

5 The Circuit Breaker Limitation does not apply to a residence homestead that qualifies for an exemption or property appraised under other subchapters of the Tax Code, such as agricultural or timber land. See TEX. TAX CODE § 23.231(c). 6 Section 25.18 provides for periodic reappraisals of property at least once every three years. TEX. TAX CODE § 25.18(b). 3 (C) the market value of all new improvements to the property.

Id. § 23.231(d).

B. Dispute over Appraised Value of WDI’s Property

WDI owns a Houston apartment complex (the Property). In 2023, HCAD and

WDI were parties in another lawsuit involving the Property. The parties settled that

suit, agreeing that the Property’s 2023 appraised value was $4,975,000.

In April 2024, HCAD sent a notice of the Property’s 2024 appraised value to

WDI. The notice stated that, “[a]s of January 1, 2024,” HCAD determined that the

market value and the appraised value of the Property for tax purposes were

$28,233,487. The notice informed WDI that, “[b]y law, we must appraise property

at market value”—meaning “the price for which [the Property] would have sold on

January 1 in the open market.”

WDI filed a protest of the Property’s 2024 appraised value with the county’s

Appraisal Review Board (ARB). In August 2024, the ARB issued its “Order

Determining Protest.” The ARB determined that HCAD’s “property appraisal [was]

incorrect and should be changed.” The order reflected that the ARB determined that

the Property’s 2024 market and appraised values were $14,515,618. The order

notified WDI that it had the right to appeal the order to district court.

WDI filed suit against HCAD, seeking judicial review of the ARB’s order. In

its amended petition, WDI alleged that the Property’s 2024 appraised value was not

4 equal and uniform when compared to other properties. WDI also alleged that the

appraised value exceeded the market value “as of the Jan. 1 date[] of valuation” and

was “therefore excessive and unlawful.” WDI asked the trial court “[to] determine

the market value[]” of the Property and, “under [Tax] Code Sections 42.24 and

42.25, reduce [the Property’s] appraised value on [the] appraisal rolls to the true

market value.”

WDI asserted that, because the Property’s 2023 appraised value of $4,975,000

was under $5 million, the Property qualified for the Circuit Breaker Limitation.

WDI claimed that, under the limitation, the Property’s maximum appraised value for

2024 was $5,970,000. This amount represented the maximum increase permitted by

the Circuit Breaker Limitation of (1) 20 percent of the Property’s 2023 appraised

value plus (2) its 2023 appraised value.7 See id. § 23.231(d)(2)(A)–(B). WDI

alleged that the ARB’s 2024 valuation of $14,515,618 was “in gross violation of

Texas law.”

WDI moved for traditional summary judgment, asserting two grounds. In its

first ground, WDI claimed that the “undisputed facts,” as shown in its summary-

judgment evidence, established that the Property’s 2024 market and appraised values

7 The Circuit Breaker Limitation also permits the market value of all new improvements to be added to the appraisal limitation, but the record does not indicate that new improvements were made to the Property in 2023. See TEX. TAX CODE § 23.231(d)(2)(C).

5 were $4,859,794, an amount less than the Property’s 2023 appraised value of

$4,975,000.

In its second ground, WDI argued that, if the trial court rejected its first

ground, then the court should grant summary judgment because the Property’s 2024

appraised value was “statutorily limited” by the Circuit Breaker Limitation. WDI

asserted that, because the Property “was appraised at $4,975,000 in 2023,” the

maximum appraised value for the Property in 2024 was $5,970,000. WDI asked the

trial court to “hold that the maximum 2024 appraised value that HCAD can set for

the subject property is 2023’s value plus 20%, i.e., $5,970,000.”

HCAD responded that the facts were not “undisputed” and asserted that

WDI’s summary-judgment evidence did not establish that the Property’s 2024

appraised value was $4,859,794. HCAD also asserted that the Circuit Breaker

Limitation did not limit the Property’s 2024 appraised value. HCAD pointed out

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Westview Drive Investments v. Harris Central Appraisal District F/K/A Harris County Appraisal District, Counsel Stack Legal Research, https://law.counselstack.com/opinion/westview-drive-investments-v-harris-central-appraisal-district-fka-texapp-2025.