Lasalle Bank Nat'l Ass'n v. White, 246 S.W.3d 616 (Tex. 2007). · Go Syfert
Lasalle Bank Nat'l Ass'n v. White, 246 S.W.3d 616 (Tex. 2007). Cases Citing This Book View Copy Cite
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cited 2× by 1 distinct case, last quoted 2010 · …carefully protecting the family homestead from foreclosure,
cited 2× by 2 distinct cases, last quoted 2009 · …long recognized a lienholder's common law right to equitable subrogation. at p. 618
126 citation events (126 in the last 25 years) across 14 distinct courts.
Strongest positive: Cindy Thompson, Individually and as Heir of Charles Thompson, and Cc & T Investments, LLC v. Mae Landry (tex, 2025-05-09)
Treatment trajectory · 2008 → 2026 · click a year to view as-of
2008 2017 2026
Top citers, strongest first. 50 distinct citers. How cited ↗
discussed Cited as authority (verbatim quote) Cindy Thompson, Individually and as Heir of Charles Thompson, and Cc & T Investments, LLC v. Mae Landry
Tex. · 2025 · quote attribution · 1 verbatim quote · confidence high
by definition, equitable remedies apply only when there is no remedy at law . . . .
discussed Cited as authority (verbatim quote) Pnc Mortgage, a Division of Pnc Bank, N.A. Successor to National City Bank and National City Mortgage, a Division of National City Bank of Indiana v. John Howard and Amy Howard (2×) also: Cited as authority (rule)
Tex. · 2023 · quote attribution · 1 verbatim quote · confidence high
by definition, equitable remedies apply only when there is no remedy at law . . . .
discussed Cited as authority (verbatim quote) Jesse Dimas Alvarado v. State
Tex. App. · 2015 · quote attribution · 1 verbatim quote · confidence high
when interpreting the texas constitution, we 'rely heavily on its literal text and must give effect to its plain language.
discussed Cited as authority (verbatim quote) Sims v. Carrington Mortgage Services, L.L.C. (2×) also: Cited as authority (rule)
5th Cir. · 2013 · signal: see, e.g. · quote attribution · 1 verbatim quote · confidence high
for over 175 years, texas has carefully protected the family homestead from foreclosure by limiting the types of liens that can be placed upon homestead property.
examined Cited as authority (verbatim quote) Harmon v. Lighthouse Capital Funding, Inc. (In Re Harmon) (3×) also: Cited as authority (rule)
Bankr. S.D. Tex. · 2011 · quote attribution · 1 verbatim quote · confidence high
we have honored equitable subrogation claims against homestead property when a refinance, even though unconstitutional, was used to pay off valid liens.
cited Cited as authority (rule) Turner Specialty Services, LLC v. Michaela Horn, Individually and as Next Friend of G.H. and M.M., Minors and Atrelle Horn
txctapp1 · 2026 · confidence medium
Ass’n v. White, 246 S.W.3d 616, 619 (Tex. 2007); see Eddington v. Dall.
discussed Cited as authority (rule) Wells Fargo Bank NA v. Moreno (2×) also: Cited "see"
N.D. Tex. · 2025 · confidence medium
Corp. v. Zepeda, 601 S.W.3d 763 , 766 (Tex. 2020) (citing LaSalle Bank Nat’l Assoc. v. White, 246 S.W.3d 616, 619 (Tex. 2007)).
examined Cited as authority (rule) Ronal Peace and Jacquetta L. Peace v. PNC Bank National Association S/B/M to National City Bank S/B/M to National City Mortgage Co. D/B/A Commonwealth United Mortgage Company, as the Successor in Interest or Assignee of National City Mortgage Co. D/B/A Commonwealth United Mortgage a Subsidiary of National City Bank of Indiana, by and Through Its Duly Authorized Mortgage Servicer PNC Mortgage, a Division of PNC Bank, N.A., Successor to National City Bank (3×) also: Cited "see"
Tex. App. · 2021 · confidence medium
“The doctrine of equitable subrogation has been repeatedly applied to preserve lien rights on homestead property.” LaSalle Bank Nat’l Ass’n v. White, 246 S.W.3d 616, 619 (Tex. 2007) (Moreover, even “[i]nvalidation of a contractual lien does not preclude equitable subrogation.”).
cited Cited as authority (rule) PNC Mortgage, a Division of PNC Bank, N.A. Succesor to National City Bank and National City Mortgage, a Division of National City Bank of Indiana v. John Howard and Amy Howard
Tex. App. · 2021 · confidence medium
LaSalle Bank Nat’l Ass’n v. White, 246 S.W.3d 616, 619 (Tex. 2007) (per curiam).
cited Cited as authority (rule) Wells Fargo Bank National Association v. Benamou
N.D. Tex. · 2021 · confidence medium
Ass’n v. White, 246 S.W.3d 616, 620 (Tex. 2007).
cited Cited as authority (rule) Kelly Pope Worley and Kevin Pope v. Chrysanthi Avinger
Tex. App. · 2019 · confidence medium
Ass’n v. White, 246 S.W.3d 616, 619 (Tex. 2007).
discussed Cited as authority (rule) Untitled Texas Attorney General Opinion
Tex. Att'y Gen. · 2018 · confidence medium
The Honorable Roland Gutierrez - Page 2 (KP-0183) LaSalle Bank Nat ·1 Ass 'n v. White, 246 S. W.3d 616, 618 (Tex. 2007) (Home-equity loans ·'permit homeowners to use the equity in their home as collateral to refinance the terms of prior debt and secure additional loans at rates more favorable than those for consumer loans.'').
discussed Cited as authority (rule) PNC Mortgage, a Division of PNC Bank, N.A. Succesor to National City Bank and National City Mortgage, a Division of National City Bank of Indiana v. John Howard and Amy Howard (2×)
Tex. App. · 2018 · confidence medium
Ass'n v. White, 246 S.W.3d 616, 619-20 (Tex. 2007) ............................................................ 35, 36 Lazarides v. Farris, 367 S.W.3d 788, 799 (Tex. App.-Houston [14th Dist.] 2012, no pet.)................ 21 viii Leonard v. Brazosport Bank of Texas, 628 S.W. 2d 216, 220 (Tex. App—Houston [14th Dist.] 1982, writ ref’d n.r.e.) .................................................................................................... 37 Lewis v. Wells Fargo Bank, N.A., 939 F.Supp.2d 634 (N.D.
examined Cited as authority (rule) Benamou v. Wells Fargo Bank National Ass'n (3×) also: Cited "see"
5th Cir. · 2018 · confidence medium
Ass’n v. White, 246 S.W.3d 616, 619 (Tex.2007) (per curiam).
discussed Cited as authority (rule) 2012 Properties, LLC v. Garland Independent School District (2×)
Tex. App. · 2015 · confidence medium
LaSalle Bank Nat’l Ass’n v. taxes often asserts a right to be subrogated to the White, 246 S.W.3d 616, 619 (Tex. 2007). ″Perhaps taxing authority’s lien.
cited Cited as authority (rule) RWH Homebuilders, LP v. Black Diamond Development LLP and Kirby Frank, Inc.
Tex. App. · 2015 · confidence medium
LaSalle Bank Nat’l Ass’n v. White, 246 S.W.3d 616, 619 (Tex. 2007).
discussed Cited as authority (rule) Gregory G. Graze and Cynthia A. Criddle v. Nationstar Mortgage, LLC
Tex. App. · 2015 · confidence medium
BACKGROUND: HOME EQUITY LOANS AND THE TEXAS CONSTITUTION Texas has a long history of carefully protecting family homesteads from foreclosure “by limiting the types of liens that can be placed upon homestead property.” LaSalle Bank Nat’l Ass’n v. White, 246 S.W.3d 616, 618 (Tex. 2007).
discussed Cited as authority (rule) Janos Farkas v. Wells Fargo Bank, N.A. And Brice Vander Linden & Wernic, P.C. N/K/A Buckley Madole, P.C. (2×) also: Cited "see, e.g."
Tex. App. · 2015 · confidence medium
For example, § 50(a)(6)(I) “prohibits home-equity loans from being ‘secured by homestead property designated for agricultural use.’” LaSalle Bank Nat’l Ass’n v. White, 246 S.W.3d 616, 619 (Tex. 2007) (quoting TEX.
cited Cited as authority (rule) The Bank of New York Mellon v. Daryapayma and Daryapayma
Tex. App. · 2015 · confidence medium
LaSalle Bank Nat’l Ass’n v. White, 246 S.W.3d 616, 619 (Tex. 2007).
cited Cited as authority (rule) Bank of New York Mellon v. Daryapayma
Tex. App. · 2015 · confidence medium
La-Salle Bank Nat’l Ass’n v. White, 246 S.W.3d 616, 619 (Tex.2007).
discussed Cited as authority (rule) Paul Flores v. Deutsche Bank National Trust Company, as Trustee for Fremont Home Loan Wells Fargo Home Mortgage, Inc. D/B/A America's Servicing Company And Brice, Vander Linden & Wernick, P.C.
Tex. App. · 2014 · confidence medium
Even Flores’s 32 See, e.g., LaSalle Bank Nat’l Ass’n v. White, 246 S.W.3d 616, 620 (Tex. 2007) (discussing the legal remedies available to a lender who provides a loan that contains both a portion that refinances a purchase money lien and a home equity portion). 19 affidavit does not state that he sought to obtain a loan secured with the equity in his home and that he believed he had received such a loan.
discussed Cited as authority (rule) DTND Sierra Investments LLC v. Deutsche Bank National Trust Company as Trustee for Ameriquest Mortgage Securities Inc., Asset-Backed Pass-Through Certificates, Series 2005-R6 (2×) also: Cited "see"
Tex. App. · 2013 · confidence medium
Ass’n v. White, 246 S.W.3d 616, 618 (Tex. 2007). -6- 04-12-00817-CV was issued, we hold the evidence shows Deutsche is entitled to equitable subrogation and allowed to step into the shoes of prior lienholders.
examined Cited as authority (rule) Lyda Swinerton Builders, Inc. v. Cathay Bank (4×)
Tex. App. · 2013 · confidence medium
LaSalle Bank Nat’l Ass’n v. White, 246 S.W.3d 616, 619 (Tex. 2007).
discussed Cited as authority (rule) Finance Commission v. Norwood
Tex. · 2013 · confidence medium
LaSalle Bank Nat’l Ass'n v. White, 246 S.W.3d 616, 618 (Tex.2007) (per curiam) ("For over 175 years, Texas has carefully protected the family homestead from foreclosure by limiting the types of liens that can be placed upon homestead property.
cited Cited as authority (rule) Sims v. Carrington Mortgage Servs., LLC
N.D. Tex. · 2012 · confidence medium
LaSalle Bank Nat’l Ass’n v. White, 246 S.W.3d 616, 618 (Tex.2007).
cited Cited as authority (rule) Deutsche Bank National Trust Company, as Indenture Trustee for New Century Home Loan Trust 2006-2 v. Stockdick Land Company
Tex. App. · 2012 · confidence medium
Ass’n v. White, 246 S.W.3d 616, 619 (Tex.2007) (equitable remedies apply only when theré is no remedy at law).
cited Cited as authority (rule) Deutsche Bank National Trust Company, as Indenture Trustee for New Century Home Loan Trust 2006-2 v. Stockdick Land Company
Tex. App. · 2012 · confidence medium
Ass’n v. White, 246 S.W.3d 616, 619 (Tex. 2007) (equitable remedies apply only when there is no remedy at law).
cited Cited as authority (rule) Belanger v. BAC Home Loans Servicing, L.P.
W.D. Tex. · 2011 · confidence medium
XVI, § 50(a)(6); LaSalle Bank Nat’l Ass’n v. White, 246 S.W.3d 616, 618 (Tex.2007) (per curiam).
examined Cited as authority (rule) Cerda v. 2004-EQR1 L.L.C. (4×) also: Cited "see, e.g."
5th Cir. · 2010 · confidence medium
LaSalle Bank Nat'l Ass'n v. White, 246 S.W.3d 616, 618 (Tex.2007) (per curiam).
cited Cited as authority (rule) Deutsche Bank National Trust Co. v. Roberts
Okla. Civ. App. · 2010 · confidence medium
The ability to refinance provides homeowners the flexibility to rearrange debt and avoid foreclosure." LaSalle Bank Nat'l Assoc. v. White, 246 S.W.3d 616, 620 (Tex.2007).
cited Cited as authority (rule) DEUTSCHE BANK NAT. TRUST CO. v. Roberts
Okla. Civ. App. · 2010 · confidence medium
The ability to refinance provides homeowners the flexibility to rearrange debt and avoid foreclosure." LaSalle Bank Nat'l Assoc. v. White, 246 S.W.3d 616, 620 (Tex.2007).
discussed Cited as authority (rule) Sheppard v. Interbay Funding, LLC (2×)
Tex. App. · 2009 · confidence medium
We also note that Texas courts have "long recognized a lienholder’s common law right to equitable subrogation." LaSalle Bank Nat’l Ass’n v. White, 246 S.W.3d 616, 618-19 (Tex.2007) (recognizing lender's equitable subrogation rights under common law and holding that lender was equitably sub-rogated to prior lienholders' interest and, thus, could pursue recovery ‘‘for the refinance portion of the loan proceeds” that were used to pay purchase-money and tax liens on homestead property); see also Benchmark Bank v. Crowder, 919 S.W.2d 657, 661 (Tex.1996) (holding that bank that loaned mo…
discussed Cited as authority (rule) Leonard Sheppard, Jr., Trustee v. Interbay Funding, LLC (2×)
Tex. App. · 2009 · confidence medium
We also note that Texas courts have "long recognized a lienholder's common law right to equitable subrogation." LaSalle Bank Nat'l Ass'n v. White , 246 S.W.3d 616, 618-19 (Tex. 2007) (recognizing lender's equitable subrogation rights under common law and holding that lender was equitably subrogated to prior lienholders' interest and, thus, could pursue recovery "for the refinance portion of the loan proceeds" that were used to pay purchase-money and tax liens on homestead property); see also Benchmark Bank v. Crowder , 919 S.W.2d 657, 661 (Tex. 1996) (holding that bank that loaned money to hom…
cited Cited as authority (rule) Harydzak v. New Horizon, LLC (In Re Harydzak)
Bankr. S.D. Tex. · 2009 · confidence medium
Ass’n v. White, 246 S.W.3d 616, 618-19 (Tex.2007) (internal citations omitted).
discussed Cited as authority (rule) Langehennig v. Ameriquest Mortgage Co. (In Re Ortegon)
Bankr. W.D. Tex. · 2008 · confidence medium
Final *436 ly, Defendant asserted that it was entitled to summary judgment on its counterclaim to enforce its right of subrogation based upon the Texas Supreme Court’s decision in LaSalle Bank N.A., a/k/a LaSalle National Bank, as Trustee, LaSalle National Bank, as Trustee Under Pooling and Servicing Agreement Dated June 1, 1999, Series 1999-2 v. Lorae White and Gerald Geistweidt, 246 S.W.3d 616, 621 (Tex.2007), reh‘g denied March 28, 2008.
discussed Cited "see" Kim-Lam Thi Vu, Eric Dick, the Dick Law Firm, Joe Radler and Joe Radler v. Texas Fair Plan Association
txctapp1 · 2026 · signal: see · confidence high
See LaSalle Bank Nat’l Ass’n v. White, 246 S.W.3d 616, 619 (Tex. 2007) (declining to engraft prohibition onto constitutional language that plain language did not convey).4 C.
discussed Cited "see" Pnc Mortgage, a Division of Pnc Bank, N.A., Successor to National City Bank and National City Mortgage, a Division of National City Bank of Indiana v. John Howard and Amy Howard
Tex. · 2021 · signal: see · confidence high
See id. (reaffirming that the Texas Constitution “does not destroy the well-established principle of equitable subrogation.” (quoting LaSalle Bank Nat’l Ass’n v. White, 246 S.W.3d 616, 619 (Tex. 2007))).
discussed Cited "see" Federal Home Loan Mortgage Corporation v. Sylvia Zepeda
Tex. · 2020 · signal: see · confidence high
The lender’s loan to Blalock did not meet those criteria. 10 Emphasis added. 11 § 50(a)(6)(Q)(x)(d); see Garofolo, 497 S.W.3d at 479, 484 (explaining that “the forfeiture remedy [is not] a constitutional remedy unto itself” but may be enforced “through a breach-of-contract claim when the constitutional forfeiture provision is incorporated into the terms of a home-equity loan”). 12 See Garofolo, 497 S.W.3d at 479 (“Section 50(a) simply has no applicability outside foreclosure.”). 13 See LaSalle Bank Nat’l Ass’n v. White, 246 S.W.3d 616, 619 (Tex. 2007) (per curiam). 14 Oury v…
cited Cited "see" Gordon M Swoboda v. Ocwen Loan Servicing, LLC And U.S. Bank National Association, as Trustee
Tex. App. · 2019 · signal: see · confidence high
See LaSalle Bank Nat’l Ass’n v. White, 246 S.W.3d 616, 620 (Tex. 2007) (per curiam).
cited Cited "see" Carrington Mortgage Services, LLC and Deutsch Bank Trust Company, as Indenture Trustee for New Century Home Equity Loan Trust 2005-2 v. Larrie Hutto and Bonnie Hutto
Tex. App. · 2017 · signal: see · confidence high
See LaSalle Bank Nat’l Ass. v. White, 246 S.W.3d 616 , 619–20 (Tex. 2007).
discussed Cited "see" Jillian Johnson v. World Alliance Financial Corp.
5th Cir. · 2016 · signal: see · confidence high
See LaSalle Bank Nat’l Ass’n v. White, 246 S.W.3d 616, 620 (Tex. 2007) (discussing equitable subrogation, and noting that “[t]he doctrine allows a third party who discharges a hen upon the property of another to step into the original lienholder’s shoes and assume the lien-holder’s right....”).
cited Cited "see" Carrington Mortgage Services, LLC and Deutsch Bank Trust Company, as Indenture Trustee for New Century Home Equity Loan Trust 2005-2 v. Larrie Hutto and Bonnie Hutto
Tex. App. · 2015 · signal: see · confidence high
See LaSalle Bank Nat’l Ass’n v. White, 246 S.W.3d 616 (Tex. 2007).
discussed Cited "see" Luis A. and Linda A. Santiago v. Novastar Mortgage, Inc.
Tex. App. · 2014 · signal: see · confidence high
See LaSalle Bank Nat’l Ass’n v. White, 246 S.W.3d 616, 620 (Tex.2007) (per curiam) (constitutional provisions governing home equity loans did not abrogate lenders’ equitable subrogation rights under common law).
cited Cited "see" Renee O'Carolan v. GMAC Mortgage Company
5th Cir. · 2014 · signal: see · confidence high
See La-Salle Bank Nat’l Ass’n v. White, 246 S.W.3d 616, 618-19 (Tex.2007) (citation omitted).
cited Cited "see" Bank of America v. Babu
Tex. App. · 2011 · signal: see · confidence high
See LaSalle Bank Nat’l Ass’n v. White, 246 S.W.3d 616, 619 (Tex.2007); First Nat’l Bank of Kerrville, 856 S.W.2d at 415 .
examined Cited "see" Gulley v. Countrywide Home Loans, Inc. (In Re Gulley) (3×) also: Cited "see, e.g."
Bankr. N.D. Tex. · 2010 · signal: see · confidence high
See LaSalle Bank, 246 S.W.3d at 618-20 . 60 .
discussed Cited "see, e.g." Sylvia Zepeda v. Federal Home Loan Mtge Corp.
5th Cir. · 2019 · signal: see also · confidence medium
See also , e.g. , LaSalle Bank , 246 S.W.3d at 618 (applying equitable subrogation for a loan impermissibly secured on homestead property designated for agricultural use); Benchmark Bank , 919 S.W.2d at 662 (upholding equitable subrogation for a loan to pay taxes unconstitutionally secured by a lien on the homestead); Farm & Home Sav. & Loan Ass'n v. Martin , 126 Tex. 417 , 88 S.W.2d 459 , 469-70 (1935) (upholding equitable subrogation for a valid mechanic's lien when the second loan was unconstitutional).
cited Cited "see, e.g." Brei v. Ben Brinck, Asset Acceptance, LLC (In re Brei)
Bankr. N.D. Tex. · 2019 · signal: see also · confidence low
See also Lasalle Bank Nat'l Assoc. v. White , 246 S.W.3d 616 , 618 (Tex. 2007).
discussed Cited "see, e.g." Wood v. HSBC Bank USA, N.A.
Tex. · 2016 · signal: see also · confidence medium
See, e.g., Tex. Land & Loan Co. v. Blalock, 76 Tex. 85 , 13 S.W. 12, 13 (1890) (holding that borrowers’ misrepresentation of homestead status of land securing debt did not “enable parties to evade the law, and incumber [sic] homesteads with liens forbidden by the constitution”); Inge v. Cain, 65 Tex. 75, 79 (1885); see also LaSalle Bank Nat’l Ass’n v. White, 246 S.W.3d 616, 620 (Tex.2007) (acknowledging invalidation of noncompliant hen, but recognizing right to equitable subrogation).
discussed Cited "see, e.g." Thomas D. Young A/K/A T. David Young v. JP Morgan Chase Bank, N.A.
Tex. App. · 2015 · signal: see also · confidence medium
Id.; see also LaSalle Bank Nat’l Ass’n v. White, 246 S.W.3d 616, 618 (Tex. 2007) (per curiam) Early immigrants used to flee to Texas to avoid harsh debtor laws for these protections, writing “G.T.T.” (Gone To Texas) on their doors.
Retrieving the full opinion text from the archive…
LASALLE BANK NATIONAL ASSOCIATION, A/K/A Lasalle National Bank, as Trustee and Lasalle National Bank, as Trustee Under the Pooling and Servicing Agreement Dated June 1, 1999, Series 1999-2, Petitioners,
v.
Lorae WHITE and Gerald Geistweidt, Respondents
06-1016.
Texas Supreme Court.
Dec 21, 2007.
246 S.W.3d 616
2007 Tex. LEXIS 1129
2007 WL 4465716
L. Frank Oliver, Lindsay Lee Lambert, Marc 0. Knisely, Henry A. Jakob and Louis Andrew Oliver, for Lasalle Bank National Association., A. Gerald Geistweidt, for Lorae White., Rebekah Marie Geistweidt, for Gerald Geistweidt.
Per Curiam.
Cited by 67 opinions  |  Published
PER CURIAM.

The Texas Constitution prohibits homestead property designated for agricultural use from being pledged to secure a home-equity loan, and mandates forfeiture of all principal and interest for loans so secured. In this case, a borrower obtained a home-equity loan secured by agricultural homestead property, disbursed a portion of the proceeds at closing to pay off constitutionally permissible purchase-money and tax liens (the “refinance portion”), and kept the remaining balance (the “cash-out portion”). The debtor defaulted on the note, and the trial court declared the entire debt, and the bank’s lien, invalid. A divided court of appeals affirmed. 217 S.W.3d 573, 579. We hold that the forfeiture penalty does not preclude the lender’s recovery of the refinance portion of the loan proceeds that were used to pay the debtor’s constitutionally permissible pre-existing debt because the lender was equitably subrogated to the prior lienhold-ers’ interests. Accordingly, we affirm in part, and reverse in part, the court of appeals’ judgment.

Lorae White executed a home-equity note, later assigned to LaSalle Bank, [1] in[*618] the principal amount of $260,000. The note recited that the transaction was an “extension of credit,” as defined by article XVI, section 50(a)(6) of the Texas Constitution. The note was secured by a lien against 10.147 acres of White’s 53.722-acre homestead property. At the time of disbursement, the lender used $185,010.51 of the loan proceeds to pay off the valid purchase-money lien against the total acreage, and another $9,410.96 to pay a state property-tax hen (the “refinance portion”). The remainder after closing costs, $57,518.50, was paid directly to White (the “cash-out portion”). White failed to make her first payment on the loan, paid only five of the monthly payments due during the first year, and thereafter stopped making payments altogether. When LaSalle filed an application for a home-equity loan foreclosure, White filed this suit seeking a declaratory judgment that the bank had forfeited all principal and interest because the loan violated the Texas Constitution. [2]

After a bench trial, the trial court found that the debt was secured by homestead property designated for agricultural use in violation of the Texas Constitution and signed a judgment quieting title free and clear of any hens or claims asserted by LaSalle. The court of appeals affirmed, holding that the Constitution mandated forfeiture of the prohibited loan and prohibited equitable subrogation for the refinance portion of the loan proceeds used to pay White’s pre-existing homestead debt. Id. We disagree that the Constitution abrogates lenders’ equitable subrogation rights under the common law.

For over 175 years, Texas has carefully protected the family homestead from foreclosure by limiting the types of liens that can be placed upon homestead property. Texas became the last state in the nation to permit home-equity loans when constitutional amendments voted on by referendum took effect in 1997. Such loans permit homeowners to use the equity in then-home as collateral to refinance the terms of prior debt and secure additional loans at rates more favorable than those for consumer loans. Although home-equity lending is now constitutionally permissible, article XIV, section 50(a)(6) of the Texas Constitution still places a number of limitations on such lending. Relevant to this appeal, the Constitution prohibits home-equity loans from being “secured by homestead property designated for agricultural use.” Tex. Const, art. XVI, § 50(a)(6)(I).

LaSalle does not here dispute the agricultural designation of White’s homestead property or that its home-equity loan to White violated the constitutional prohibition. Nor, for purposes of this appeal, does LaSalle challenge its forfeiture of principal, interest, and liens related to the cash-out portion of the loan. [3] LaSalle does contend, however, that it is entitled to an equitable lien on White’s homestead for money that it disbursed to pay constitutionally valid indebtedness.

Texas has long recognized a lien-holder’s common law right to equitable subrogation. See Benchmark Bank v. Crowder, 919 S.W.2d 657, 661 (Tex.1996); Faires v. Cockrill, 88 Tex. 428, 31 S.W.[*619] 190,194 (1895); Oury v. Saunders, 77 Tex. 278, 13 S.W. 1080, 1031 (1890). The doctrine allows a third party who discharges a lien upon the property of another to step into the original lienholder’s shoes and assume the lienholder’s right to the security interest against the debtor. First Nat’l Bank of Kerrville v. O’Dell, 856 S.W.2d 410, 415 (Tex.1993) (citing Faires, 31 S.W. at 194). The doctrine of equitable subro-gation has been repeatedly applied to preserve lien rights on homestead property. See, e.g., Benchmark, 919 S.W.2d at 661; Farm & Home Sav. & Loan Ass’n v. Martin, 126 Tex. 417, 88 S.W.2d 459, 469-70 (1935). If applied in this case, LaSalle’s payment of the balance of the purchase-money mortgage and the accrued taxes on White’s property would entitle it to assume those lienholders’ security interests in the homestead. White contends, though, and the court of appeals held, that article XVI, section 50(e) of the Texas Constitution abrogates all equitable subrogation rights, including those that arise from payment of constitutionally valid debts. 217 S.W.3d at 578-79. We disagree.

Article XVI, section 50(e), in its entirety, provides:

A refinance of debt secured by a homestead and described by any subsection under Subsections (a)(l)-(a)(5) that includes the advance of additional funds may not be secured by a valid lien against the homestead unless:
(1) the refinance of the debt is an extension of credit described by Subsection (a)(6) of this section; or
(2) the advance of all the additional funds is for reasonable costs necessary to refinance such debt or for a purpose described by Subsection (a)(2), (a)(3), or (a)(5) of this section.

Tex. Const, art. XVI, § 50(e). When interpreting the Texas Constitution, we “rely heavily on its literal text and must give effect to its plain language.” Stringer v. Cendant Mortgage Corp., 23 S.W.3d 353, 355 (Tex.2000); Republican Party of Tex. v. Dietz, 940 S.W.2d 86, 89 (Tex.1997). Section 50(e) contains no language that would indicate displacement of equitable common law remedies was intended, and we decline to engraft such a prohibition onto the constitutional language. La-Salle’s equitable subrogation claim does not derive from its contractually refinanced debt and accompanying hen, for which section 50(e) mandates forfeiture. Instead, LaSalle’s claim arises in equity from its prior discharge of constitutionally valid purchase-money and tax hens. By definition, equitable remedies apply only when there is no remedy at law, and the legal forfeiture that article 50(e) imposes does not destroy the well-established principle of equitable subrogation.

We have honored equitable subrogation claims against homestead property when a refinance, even though unconstitutional, was used to pay off vahd hens. See Benchmark, 919 S.W.2d at 661. In Benchmark, the homeowners borrowed money from Benchmark Bank’s predecessor to pay federal taxes and signed a note giving the bank a deed of trust that purported to create a hen against the homestead. When the homeowners defaulted and the bank sought to foreclose the hen, the homeowners claimed the hen was invahd because the then-existing version of article XVI, section 50 did not specifically identify federal tax hens as a vahd indebtedness against homestead property. We held that, under the Supremacy Clause of the United States Constitution, the IRS could obtain and enforce a federal tax hen against Texas homestead property. Id. at 660. We further held that Benchmark was equitably subrogated to the federal tax hen against the homestead, even though the Texas Constitution did not recognize[*620] the validity of a federal tax lien against the property and the Supremacy Clause did not require us to do so when the IRS no longer held the lien. Id. at 661. We emphasized that, “[o]nce valid, the lien does not become invalid against the homestead simply because the original debt has been refinanced.” Id. To hold otherwise, we said, would defeat the purpose of homestead protection: “Homestead owners must have the ability to renew, rearrange, and readjust the encumbering obligation to prevent a loss of the homestead through foreclosure.” Id. (citing Machicek v. Barcak, 141 Tex. 165, 170 S.W.2d 715, 717 (1943)).

White contends Benchmark is inapposite to this case because it was based on the Texas Constitution as it existed before passage of the home-equity amendment in 1997. If section 50(e) is to have any meaning whatsoever, White argues, it must operate to change the law surrounding the forfeiture of liens. In effect, White contends article XVI, section 50(e) overrules Benchmark. But as we have noted, section 50(e) does not discuss equitable remedies. And section 50(e) need not be read to prohibit equitable subrogation of valid liens in order to have meaning. The contractual loan transaction between LaSalle and White involved an “extension of credit” under section 50(e), which the bank here concedes was forfeited by securing the debt with property designated for agricultural use. LaSalle’s equitable subrogation claim, though, arises not from the extension-of-credit transaction but from its payment of the pre-existing, constitutionally valid liens, which allowed the bank to step into the shoes of the prior lienholders. See Oury, 13 S.W. at 1031. Thus, section 50(e) operates here to invalidate any liens related to the cash-out portion of the loan.

Invalidation of a contractual lien does not preclude equitable subrogation. In Texas Land & Loan Co. v. Blalock, we held that, although a home-equity loan was invalid under the Texas Constitution, the lender was entitled to equitable subrogation to the extent of the prior valid purchase-money lien that the loan had been used to discharge. 76 Tex. 85, 13 S.W. 12, 13-14 (1890). In Faires, too, we stated that “[o]ne who discharges the vendor’s lien upon lands, even the homestead, either by paying as surety, or at the request of the debtor, or at a judicial sale, which, for irregularities in the process, fails to convey the title, is entitled to be subrogated to the lien of the creditor to the extent of the payment so made.” 31 S.W. at 194 (emphasis added). And again in Martin, we reiterated that the refinancing lender which discharged a valid mechanic’s lien was entitled to equitable subrogation, even though such a lien on the homestead would otherwise violate the constitution. Martin, 88 S.W.2d at 469-70. Throughout our jurisprudence, we have stressed that the doctrine of equitable subrogation works to protect homestead property. Without equitable subrogation, lenders would be hesitant to refinance homestead property due to increased risk that they might be forced to forfeit their liens. The ability to refinance provides homeowners the flexibility to rearrange debt and avoid foreclosure. Benchmark, 919 S.W.2d at 661; Machicek, 170 S.W.2d at 717. Article XVI, section 50(e) does not abrogate this longstanding common law principle or preclude LaSalle Bank’s entitlement to equitable subrogation for the refinance portion of the loan proceeds that were used to extinguish White’s constitutionally permissible purchase-money and property-tax liens.

Accordingly, without hearing oral argument, we grant the petition for review, reverse the court of appeals’ judgment in part, affirm in part, and remand to the trial court for further proceedings consis[*621] tent with this opinion. See Tex.R.App. P. 59.1.

1

. We refer to the petitioner, LaSalle Bank National Association, a/k/a LaSalle National[*618] Bank, as Trustee and LaSalle National Bank, as Trustee Under the Pooling and Servicing Agreement dated June 1, 1999, Series 1999-2, as “LaSalle Bank.”

2

. Respondent Gerald Geistweidt was added to the suit after White conveyed an interest in the property to him.

3

. When, a home-equity loan violates the terms of section 50(a)(6), section 50(a)(6)(Q)(x) provides that the lender forfeits the principal and interest, while section 50(e) discusses forfeiture of liens.