Dallas County Appraisal District v. Joseph J. Lal

The Dallas County Appraisal District appeals from a judgment for appellee, Joesph J. Lal, on his claim of grossly excessive valuation in the assessment of ad valorem taxes on his property. Lal sued the Appraisal District as well as certain taxing entities for grossly excessive valuation under section 1 of Article VIII of the Texas Constitution. The Appraisal District and the taxing authorities moved for summary judgment to dismiss the action for want of jurisdiction because Lal had not exhausted his administrative remedies under the Property Tax Code. Although the judge declined to grant summary judgment dismissing the cause, he did grant a partial summary judgment finding that Lal had failed to comply with the statutory administrative provisions contained in chapters 41 and 42 of the Property Tax Code. Then, the trial Judge heard testimony on Lals action for grossly excessive valuation. At the conclusion of the evidence, the trial court found that the Districts appraisal of Lals property at $1,596,556 was grossly excessive. The Judge, then, fixed the appraised fair market value at $883,202 and set aside all taxes, penalties, and interest assessed against Lals property in excess of $883,202. On appeal, the Appraisal District reasserts that the trial court was without subject matter jurisdiction to hear Lals claim, since Lal failed to comply with the procedures of chapters 41 and 42 of the Property Tax Code. We agree and hold that the judgment is void. Accordingly, we dismiss Lals cause of action.