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Cameron Appraisal Dist. v. Rourk

Supreme Court of Texas
Jun 2, 2006
194 S.W.3d 501 (Tex. 2006)

Summary

holding that taxpayers were required to exhaust their administrative remedies before bringing suit on constitutional claims because they sought not only a declaration on the legal issue of whether the constitution prohibited taxation of trailers, but also to set aside their individual assessments

Summary of this case from Clint Indep. Sch. Dist. v. Marquez

Opinion

No. 04-0359.

June 2, 2006.

Appeal from the 357th District Court, Cameron County, Rolando Olvera, J.

Ernest C. Garcia, Judith A. Hargrove, Linebarger Goggan Blair Sampson, LLP, Austin, for Petitioner.

Ruben R. Pena, Law Offices of Ruben R. Pena, P.C., Harlingen, for Respondents.

Richard S. Talbert, Law Offices of Talbert McDaniel, Weslaco, for Amicus Curiae.

Gene Phagan, Mission, pro se.


The Cameron Appraisal District assessed ad valorem taxes against the owners of 34 travel trailers for the tax years 2000 and 2001. After some but not all filed unsuccessful administrative protests and then timely appeals in the district court, the latter (1) dismissed for lack of jurisdiction the claims by those who had not exhausted administrative remedies, (2) granted summary judgment against the remainder because their trailers were taxable as a matter of law, and (3) refused to certify a class action. The court of appeals reversed, finding error in all three rulings. 131 S.W.3d 285 (Tex.App.-Corpus Christi 2004). Because exhaustion of administrative remedies was mandatory, we reverse. See TEX. GOV'T CODE § 22.225(d).

Although remanding to the trial court for class certification, the court of appeals appeared to approve a class of "[a]ll individuals located in Cameron County, Texas who own park model or travel trailers located on r.v. or travel trailer parks, who have been either previously taxed and/or whom the Cameron County Appraisal District has sought to appraise for the purpose of placing the park model or travel trailers on the tax rolls of various taxing entities within Cameron County, Texas and whose park models and/or travel trailers . . . are not held or used for the production of income." 131 S.W.3d at 300.

The Texas Tax Code provides detailed administrative procedures for those who would contest their property taxes. See §§ 41.01-.71. Administrative decisions are final if not appealed to the district court within 45 days. Id. § 42.21(a). The administrative procedures are "exclusive" and most defenses are barred if not raised therein. Id. § 42.09. Thus, we have repeatedly held that "a taxpayer's failure to pursue an appraisal review board proceeding deprives the courts of jurisdiction to decide most matters relating to ad valorem taxes." Matagorda County Appraisal Dist. v. Coastal Liquids Partners, L.P., 165 S.W.3d 329, 331 (Tex. 2005); Gen. Elec. Credit Corp. v. Midland Cent. Appraisal Dist., 826 S.W.2d 124, 125 (Tex. 1992) (per curiam); Webb County Appraisal Dist. v. New Laredo Hotel, Inc., 792 S.W.2d 952, 954-55 (Tex. 1990); see also In re Entergy Corp., 142 S.W.3d 316, 321-22 (Tex. 2004) (applying the same rule generally when an agency has exclusive original jurisdiction).

Those who do not file administrative protests may still assert that (1) they did not own the property, or (2) the property was outside the boundaries of the taxing unit. See TEX. TAX CODE § 42.09(b). The class here asserts neither.

Here, the summary judgment record establishes that some of the named taxpayers pursued administrative remedies and filed timely appeals, but others did not. The record does not indicate how many unnamed class members might be in either category. By mandating class certification of all claims nonetheless, the court of appeals allowed taxpayers to bypass the statutorily required administrative remedies. A class action cannot be used to alter these statutory prerequisites to taxpayer recovery. See Henry Schein, Inc. v. Stromboe, 102 S.W.3d 675, 693 (Tex. 2003); Southwestern Ref. Co. v. Bernal, 22 S.W.3d 425, 437 (Tex. 2000).

The court of appeals held the exhaustion requirements inapplicable because purely legal and constitutional questions were involved here. 131 S.W.3d at 292. We disagree. In addition to claiming that taxing their trailers was unconstitutional, the taxpayers claim that their trailers were nontaxable "recreational vehicles" rather than taxable "manufactured homes" due to their size, shape, and intended use. See TEX. TAX CODE § 11.14 (incorporating by reference id. § 11.432(c), TEX. OCC. CODE § 1201.003(9) (15), and 24 C.F.R. § 3282.8(g)).

The taxpayers here are seeking more than a declaration that taxing trailers is unconstitutional — they are seeking to have their individual assessments set aside. While the former claim need not be brought administratively, the latter must. See Texas Workers' Comp. Comm'n v. Garcia, 893 S.W.2d 504, 519 (Tex. 1995).

The Texas Constitution expressly allows the Legislature to bestow exclusive original jurisdiction on administrative bodies. See TEX. CONST. art. V, § 8. There is no question the Legislature intended to do so here. By finding "no sound reason" to require exhaustion, see 131 S.W.3d at 292, the court of appeals simply substituted its own judgment for that of the Legislature. Accordingly, the court of appeals erred in reversing the trial court's partial dismissal and requiring certification of a class of taxpayers who had failed to pursue administrative remedies.

We agree, however, with the court of appeals that fact issues preclude finding the remaining taxpayers' trailers taxable as a matter of law as "manufactured homes" rather than "recreational vehicles." Whether a class can be certified as to those claims is a matter that must be decided by the trial court in the first instance. See Schein, 102 S.W.3d at 700. Accordingly, without hearing oral argument, see TEX. R. APP. P. 59.1, we reverse the court of appeals' judgment in part and remand to the trial court for further proceedings.


Summaries of

Cameron Appraisal Dist. v. Rourk

Supreme Court of Texas
Jun 2, 2006
194 S.W.3d 501 (Tex. 2006)

holding that taxpayers were required to exhaust their administrative remedies before bringing suit on constitutional claims because they sought not only a declaration on the legal issue of whether the constitution prohibited taxation of trailers, but also to set aside their individual assessments

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holding claim seeking declaration that tax is unconstitutional need not be brought administratively, but claim seeking to set aside individual tax assessment, even though premised on claim of unconstitutionality, must be brought administratively

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holding that application of the exclusive remedies provision in Tax Code section 42.09 deprives courts of subject-matter jurisdiction

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holding claim seeking declaration that tax is unconstitutional "need not be brought administratively" through tax protest procedure before asserting that claim in district court but claim seeking to set aside individual tax assessment, even though premised on claim of unconstitutionality, must be brought administratively through tax protest procedure

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holding appraisal review boards have exclusive original jurisdiction over property tax protests

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holding that "a taxpayer's failure to pursue an appraisal review board hearing deprives the courts of jurisdiction" to set aside individual assessments

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holding appraisal review boards have exclusive original jurisdiction over property tax protests

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holding that, "Because exhaustion of administrative remedies was mandatory, we reverse."

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concluding taxpayer's failure to operate within administrative framework "deprives the courts of jurisdiction to decide most matters relating to ad valorem taxes."

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rejecting argument that exhaustion of administrative remedies was not required “because purely legal and constitutional questions were involved” and holding that taxpayers who were not merely seeking a declaration that the taxes were unconstitutional but instead sought “to have their individual assessments set aside” must exhaust administrative remedies

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rejecting argument that exhaustion of administrative remedies was not required "because purely legal and constitutional questions were involved" and holding that taxpayers who were not merely seeking a declaration that the taxes were unconstitutional but instead sought "to have their individual assessments set aside" must exhaust administrative remedies

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recognizing the Tax Code provides detailed administrative procedures for those who contest their property taxes, which are "exclusive," and most defenses are barred if not raised through the administrative process

Summary of this case from Public v. Galveston

In Rourk, the Texas Supreme Court noted that the "Texas Tax Code provides detailed administrative procedures for those who would contest their property taxes;" "Administrative decisions are final if not appealed to the district court within 45 days;" and "administrative procedures are 'exclusive' and most defenses are barred if not raised therein." Rourk, 194 S.W.3d at 502.

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noting that a claim that a tax on camper trailers was unconstitutional “need not be brought administratively,” but the claimants must exhaust their administrative remedies for a claim that the trailers are “nontaxable” and “seeking to have their individual assessments set aside”

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In Rourk, however, the supreme court discussed the limitations on the scope of this exception in cases involving ad valorem taxes.

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dismissing for want of jurisdiction UDJA claims by taxpayers due to failure to exhaust administrative remedies

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requiring adherence to the Property Tax Code's administrative framework when taxpayer seeks to set aside tax assessments but not when asserting purely constitutional challenges

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requiring adherence to Tax Code's administrative framework when taxpayer seeks to set aside tax assessments but not when asserting purely constitutional challenges

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In Rourk, the supreme court reversed a court of appeals' decision that the requirement to exhaust administrative remedies was inapplicable because the taxpayers had raised purely legal and constitutional questions.

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requiring exhaustion of remedies as to a claim to set aside an assessment on constitutional grounds

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requiring exhaustion of remedies as to a claim to set aside an assessment on constitutional grounds

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describing appraisal-review-board proceeding as administrative

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In Rourk, our high court indicated that section 42.09 expresses this intent of the Texas Legislature, and our high court concluded that the trial court properly dismissed for lack of jurisdiction the claims of taxpayers who did not pursue the administrative remedies provided by the Tax Code.

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In Cameron Appraisal District v. Rourk, 194 S.W.3d 501 (Tex. 2006), the supreme court stated that the legislature intended to bestow exclusive original jurisdiction in ad valorem tax cases on the appraisal review boards.

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Case details for

Cameron Appraisal Dist. v. Rourk

Case Details

Full title:CAMERON APPRAISAL DISTRICT, Petitioner, v. Thora O. ROURK, et al.…

Court:Supreme Court of Texas

Date published: Jun 2, 2006

Citations

194 S.W.3d 501 (Tex. 2006)

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