"If there is one doctrine more deeply rooted than any other in the process of constitutional adjudication, it is that we ought not to pass on questions of constitutionality . . . unless such adjudication is unavoidable." Tha Dang Nguyen v. State, 359 S.W.3d 636, 645-46 (Tex. Crim. App. 2012) (quoting Spector Motor Serv. v. McLaughlin, 323 U.S. 101, 105 (1944)); see Ex parte Salfen, 618 S.W.2d 766, 770 (Tex. Crim. App. 1981) ("It is well-settled that the constitutionality of a statute will not be determined in any case unless such a determination is absolutely necessary to decide the case in which the issue is raised."); City of San Antonio v. Summerglen Prop. Owners Ass'n, 185 S.W.3d 74, 87 (Tex. App.-San Antonio 2005, pet. denied) ("[A] court will not rule on a constitutional question, although properly presented by the record, if there is some other ground upon which the case may be disposed.").

Defects in the “process of adopting an annexation ordinance” cannot be challenged outside of a quo warranto proceeding. City of San Antonio v. Summerglen Prop. Owners Ass'n Inc., 185 S.W.3d 74, 83 (Tex.App.-San Antonio 2005, pet. denied). For example, in City of Wilmer v. Laidlaw Waste Sys. (Dallas), Inc., a private party, who challenged a city's annexation conducted under section 43.024, complained that “[o]ne of the persons who signed the annexation petition was not an inhabitant of the area annexed.”