Harris Cnty. Appraisal Dist. v. IQ Life Scis. Corp.
| Decision Date | 13 October 2020 |
| Docket Number | NO. 14-18-00894-CV,14-18-00894-CV |
| Parties | HARRIS COUNTY APPRAISAL DISTRICT, Appellant v. IQ LIFE SCIENCES CORPORATION, Appellee |
| Court | Texas Court of Appeals |
PLURALITY OPINION
Appellee IQ Life Sciences Corporation filed a suit for judicial review against appellant, Harris County Appraisal District (HCAD), in district court after the Appraisal Review Board dismissed IQ Life Sciences's section 25.25(d) motion for correction of its property taxes and section 41.411 protest of its property taxes for tax years 2013 through 2015. See Tex. Tax Code Ann. §§ 25.25(d), 41.411. HCAD filed a plea to the jurisdiction arguing that the trial court did not have subject-matter jurisdiction because IQ Life Sciences did not timely file either the motion for correction or protest. The trial court denied HCAD's plea. Because we conclude that the trial court does not have subject-matter jurisdiction over IQ Life Sciences's claims, we reverse the trial court's denial of HCAD's plea and dismiss IQ Life Sciences's claims for lack of subject-matter jurisdiction.1
It is undisputed that IQ Life Sciences owned business personal property in Harris County on January 1 of each tax year at issue in this case, 2013, 2014, and 2015. It is also undisputed that IQ Life Sciences did not protest the appraised value of the business personal property for any of the tax years at issue prior to February 1 of each year after the tax year. According to IQ Life Sciences, it did not file protests because it did not receive notices of the appraised value from HCAD for the tax years at issue. IQ Life Sciences did, however, pay the exact amount shown on its property tax bills before the February 1 delinquency date for each tax year at issue.
IQ Life Sciences paid the 2013 taxes on January 21, 2014, the 2014 taxes on January 28, 2015, and the 2015 taxes on December 31, 2015 and January 20, 2016.2 As demonstrated by its own records, IQ Life Sciences therefore had actual notice of the amount of business property taxes it owed for each tax year at issue in this appeal. Even though IQ Life Sciences had actual knowledge of those taxes, and paid the exact amount of taxes shown on its tax bill prior to the delinquency date during each year at issue in this appeal, it did not protest or otherwise complain about the appraisal or assessment of its property at the time of each payment.
IQ Life Sciences instead waited until August 11, 2017 to file a motion for correction asserting that the appraised value of its personal property for the years 2013, 2014, and 2015, exceeded by more than one-third the correct appraised value. See Tex. Tax Code Ann. § 25.25(d) (). IQ Life Sciences also filed on that same day protests under section 41.411 asserting that HCAD had failed to send during 2013, 2014, and 2015, the notice of appraised value called for by section 25.19 of the Property Tax Code. See id. at §§ 25.19 (), 41.411(a) (). The Harris County Appraisal Review Board (ARB) determined that it had no jurisdiction to grant any of the relief requested by IQ Life Sciences and it dismissed IQ Life Sciences's motion and protests.
IQ Life Sciences then filed suit asking the district court to order HCAD (1) to correct the 2013, 2014, and 2015 appraised values of its personal property pursuant to section 25.25(d) of the Property Tax Code and (2) to provide IQ Life Sciences with notices of appraisal for the tax years at issue and provide a hearing regarding IQ Life Sciences's protest of those appraised values. HCAD filed a plea to the jurisdiction arguing the trial court did not have subject-matter jurisdiction over IQ Life Sciences's suit because IQ Life Sciences did not timely exhaust its administrative remedies as required by the Property Tax Code. The trial court denied the plea.
HCAD filed a motion for reconsideration. In response, IQ Life Sciences argued that because it had timely paid all taxes for the tax years at issue, no taxes ever became delinquent. As a result of its timely payment, IQ Life Sciences asserted there was no deadline for it to file a lack-of-notice protest for those years. IQ Life Sciences argued in the alternative that section 41.44(c-3) of the Property Tax Code extended the deadline to file a lack-of-notice protest because it never received a tax bill from any taxing unit for any of the three years at issue. See Tex. Tax Code Ann. § 41.44(c-3) (). The trial court denied HCAD's motion for reconsideration. HCAD then filed this interlocutory appeal. See Tex. Civ. Prac. & Rem. Code § 51.014(a)(8).
HCAD raises three issues on appeal, all challenging the trial court's denial of its plea to the jurisdiction. While we ultimately address the arguments raised in each of HCAD's issues, we approach them from the perspective of IQ Life Sciences two claims raised in its suit below.
HCAD's issues all challenge whether the trial court had subject-matter jurisdiction to consider IQ Life Sciences's claims. The existence of subject-matter jurisdiction is a question of law that can be challenged by a plea to the jurisdiction. Klumb v. Houston Mun. Emps. Pension Sys. , 458 S.W.3d 1, 8 (Tex. 2015) ; Tex. Dep't of Parks & Wildlife v. Miranda , 133 S.W.3d 217, 226 (Tex. 2004). We review a trial court's ruling on a plea de novo. See Miranda , 133 S.W.3d at 226, 228 ; Woodway Drive LLC v. Harris Cty. Appraisal Dist. , 311 S.W.3d 649, 651 (Tex. App.—Houston [14th Dist.] 2010, no pet.).
When, as here, a plea to the jurisdiction challenges the existence of jurisdictional facts, we consider relevant evidence submitted by the parties when necessary to resolve the jurisdictional issues. See Miranda , 133 S.W.3d at 227. The movant, in this case HCAD, must meet the summary-judgment standard of proof by conclusively demonstrating that the trial court lacks subject-matter jurisdiction. See id. at 227–28. We credit as true all evidence favoring the nonmovant and draw all reasonable inferences and resolve any doubts in the nonmovant's favor. Id. at 228. If the evidence creates a fact question regarding the jurisdictional issue, then the trial court may not grant the plea, and the fact issue will be resolved at trial by the factfinder. Id. at 227–28. If relevant evidence is undisputed or fails to raise a fact question on the jurisdictional issue, then the trial court rules on the plea as a matter of law. Id. at 228.
This appeal presents questions of statutory construction, which we also review de novo. Texas Dep't of Transp. v. Needham , 82 S.W.3d 314, 318 (Tex. 2002). When construing statutes, our primary objective is to give effect to the legislature's intent. Willacy Cty. Appraisal Dist. v. Sebastian Cotton & Grain, Ltd. , 555 S.W.3d 29, 38 (Tex. 2018). We rely on the plain meaning of the text as expressing legislative intent unless a different meaning is supplied by legislative definition or is apparent from the context, or the plain meaning leads to absurd results. Id. We presume that the legislature intended the entire statute to be effective. Vitol, Inc. v. Harris Cty. Appraisal Dist. , 529 S.W.3d 159, 171 (Tex. App.—Houston [14th Dist.] 2017, no pet.). We also presume that the legislature chose a statute's language with care, intentionally including each word chosen, and omitting words purposefully. Id. , at 168. Another fundamental principle of statutory construction is that when construing a statute, a reviewing court must consider the act as a whole and not just as single phrases, clauses, or sentences. Fredericksburg Care Co. v. Perez , 461 S.W.3d 513, 520 (Tex. 2015). We must give effect to each provision of a statute so that none is rendered meaningless or mere surplusage. TIC Energy & Chem., Inc. v. Martin , 498 S.W.3d 68, 74 (Tex. 2016). Therefore, when construing the provisions of the Property Tax Code at issue in this appeal, we must consider how each "provision fits within the narrow framework of the tax-appraisal protest scheme and within the broader scope of the Property Tax Code as a whole." Willacy Cty. Appraisal Dist. , 555 S.W.3d at 39.
The overall purpose of the Property Tax Code is to assure "the orderly collection of revenue so that the functions of government should not be dependent upon the outcome of a multitude of lawsuits," while also ensuring that property owners have been given adequate time to file their protests. See Valero Transmission Co. v. Hays Consol. Indep. Sch. Dist. , 704 S.W.2d 857, 859, n.1 (Tex. App.—Austin 1985, writ ref'd n.r.e.) (); see also Willacy Cty. Appraisal Dist. , 555 S.W.3d at 40 (citing Anderton v. Rockwall Cent. Appraisal Dist. , 26 S.W.3d 539, 543 (Tex. App.—Dallas 2000, pet. denied) ). To fulfill this purpose, the Property Tax Code provides detailed administrative procedures which are exclusive for anyone wanting to contest their property taxes. See Tex. Tax Code § 41.41 (); Vitol, Inc. , 529 S.W.3d at 166 ; Appraisal Review Bd. Of Harris Cty. Appraisal Dist. v. O'Connor & Assocs. , 267 S.W.3d 413, 419 (Tex. App.—Houston [...
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