property owner rule (Texas) · Go Syfert
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property owner rule in Texas

37 Texas opinions name it 4 courts 1985–2026 4 in the last five years

The cases below were cited by Texas courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (14)

CaseFollowedCited
Natural Gas Pipeline Co. of America v. Justissgreen
tex · 2012 · cited in 12 Texas opinions naming this issue, 2015–2026
2 sentences

2024See Natural Gas Pipeline Co. of America v. Justiss, 397 S.W.3d 150 , 156–57 (Tex. 2012) (describing contours of the property owner rule where lay witness owner may testify to property value).

2020See Bustamante, 529 S.W.3d at 462 ; Justiss, 397 S.W.3d at 156 ; but cf. Miller v. Argumaniz, 479 S.W.3d 306 , 312–13 (Tex. App.—El Paso 2015, pet. denied) (holding that a four-year-old appraisal sufficed to provide a factual basis for the valuation testimony pursuant to Rule 701 and the property owner rule); Long Island Village Owners Ass'n v. Berry, No. 13-14-00363-CV, 2016 WL 1072856 , at *15 (Tex. App.—Corpus Christi–Edinburg Mar. 17, 2016, pet. denied) (mem. op.) (approving property owner valuation supported by the original purchase price and the most recent tax statement); RWH Homebuilde

1012
Sullivan v. Stategreen
texcrimapp · 1986 · cited in 4 Texas opinions naming this issue, 2015–2023
2 sentences

2023See Sullivan, 701 S.W.2d at 909 ; Smiles [v. State], 298 S.W.3d [716,] 719 [(Tex. App.— Houston [14th Dist.] 2009, no pet.)]. 9 Bullock, 479 S.W.3d at 427–28.

2015See Sullivan, 701 S.W.2d at 909 ; Smiles, 298 S.W.3d at 719 . 8 The evidence is legally sufficient.

44
Webb County Appraisal District v. New Laredo Hotel, Inc.green
tex · 1990 · cited in 4 Texas opinions naming this issue, 2012–2016
2 sentences

2016Appraisal Dist. v. New Laredo Hotel, 792 S.W.2d 952, 954 (Tex. 1990) (discussing protest procedure)).

2012Appraisal Dist. v. New Laredo Hotel, 792 S.W.2d 952, 954 (Tex.1990) (discussing protest procedure).

44
Speedy Stop Food Stores, Ltd. v. Reid Road Municipal Utility District No. 2green
texapp · 2009 · cited in 3 Texas opinions naming this issue, 2010–2010
2 sentences

2010Speedy Stop Food Stores, Ltd. v. Reid Road Municipal Utility District No. 2., 282 S.W.3d 652, 659 (Tex.App.-Houston [14th Dist.] 2009, pet. filed).

2010Speedy Stop Food Stores, Ltd. v. Reid Road Municipal Utility District No. 2., 282 S.W.3d 652, 659 (Tex.App.--Houston [14th Dist.] 2009, pet. filed).

33
Porras v. Craiggreen
tex · 1984 · cited in 3 Texas opinions naming this issue, 2011–2018
2 sentences

2018Under the property-owner rule, an owner stands qualified to testify to the value of the owner’s property; nonetheless, as set forth in the Supreme Court of Texas’s most recent pronouncement, the testimony must meet the “same requirements as any other opinion evidence.”18 The property-owner rule falls under Texas Rule of Evidence 701, which allows a lay witness to provide opinion testimony if the testimony is (a) rationally based on the witness’s perception and (b) helpful to a clear understanding of the witness’s testimony or the determination of a fact in issue.19 Based on the presumption tha

2015The property-owner rule establishes that an owner is qualified to testify to the value of his property; nonetheless, the Supreme Court of Texas requires that such testimony meet the “same requirements as any other opinion evidence.” Natural Gas Pipeline Co. of Am. v. Justiss, 397 S.W.3d 150, 156 (Tex.2012) (quoting Porras v. Craig, 675 S.W.2d 503, 504 (Tex.1984)) (internal quotations omitted).

23
Hanford-Southport, LLC. v. City of San Antonio, Acting by and Through the San Antonio Water Systemgreen
texapp · 2012 · cited in 2 Texas opinions naming this issue, 2015–2015
2 sentences

2015See Hanford-Southport, 387 S.W.3d at 850 (explaining that if property owner does not remove deposit from custody of trial court, he may contest condemnor’s ability to take property as well as amount of award); Duncan v. Calhoun Cnty.

2015See Hanford-Southport, 387 S.W.3d at 850 (explaining that if property owner does not remove deposit from custody of trial court, he may contest condemnor’s 28 ability to take property as well as amount of award); Duncan v. Calhoun Cnty.

22
First Bank of Deer Park v. Harris Countygreen
texapp · 1991 · cited in 2 Texas opinions naming this issue, 2011–2011
2 sentences

2011See First Bank of Deer Park, 804 S.W.2d at 594-95 .

2011See First Bank of Deer Park , 804 S.W.2d at 594–95 .

22
Reid Road Municipal Utility District No. 2 v. Speedy Stop Food Stores, Ltd.green
tex · 2011 · cited in 3 Texas opinions naming this issue, 2012–2015
2 sentences

2015See Reid Road, 337 S.W.3d at 855 (officer of property owner’s general partner was not qualified to testify to value of partnership’s property under the property-owner rule because the general partner was not the owner of the partnership’s property). –10– This property-owner rule falls under rule of evidence 701, “which allows a lay witness to provide opinion testimony if it is (a) rationally based on the witness’s perception and (b) helpful to a clear understanding of the witness’s testimony or the determination of a fact in issue.” Natural Gas Pipeline Co. of Am. v. Justiss, 397 S.W.3d 150, 1

2015See Reid Road, 337 S.W.3d at 855 (officer of property owner’s general partner was not qualified to testify to value of partnership’s property under the property-owner rule because the general partner was not the owner of the partnership’s property). –10– This property-owner rule falls under rule of evidence 701, “which allows a lay witness to provide opinion testimony if it is (a) rationally based on the witness’s perception and (b) helpful to a clear understanding of the witness’s testimony or the determination of a fact in issue.” Natural Gas Pipeline Co. of Am. v. Justiss, 397 S.W.3d 150, 1

13
Marcela and Jose Bustamante, as Next Friends of D.B. v. Enrique N. Ponte, Jr., M.D. and Pediatrix Medical Services, Inc.green
tex · 2017 · cited in 1 Texas opinions naming this issue, 2020–2020
1 sentence

2020See Bustamante, 529 S.W.3d at 462 ; Justiss, 397 S.W.3d at 156 ; but cf. Miller v. Argumaniz, 479 S.W.3d 306 , 312–13 (Tex. App.—El Paso 2015, pet. denied) (holding that a four-year-old appraisal sufficed to provide a factual basis for the valuation testimony pursuant to Rule 701 and the property owner rule); Long Island Village Owners Ass'n v. Berry, No. 13-14-00363-CV, 2016 WL 1072856 , at *15 (Tex. App.—Corpus Christi–Edinburg Mar. 17, 2016, pet. denied) (mem. op.) (approving property owner valuation supported by the original purchase price and the most recent tax statement); RWH Homebuilde

11
Sharifi v. Steen Automotive, LLCgreen
texapp · 2012 · cited in 1 Texas opinions naming this issue, 2017–2017
2 sentences

2017See Sharifi, 370 S.W.3d at 150 .

2017See Sharifi, 370 S.W.3d at 150 ; see also Natural Gas Pipeline, 397 S.W.3d at 159 .

11
Brennan v. City of Willow Parkgreen
texapp · 2012 · cited in 1 Texas opinions naming this issue, 2016–2016
1 sentence

2016See Brennan, 376 S.W.3d at 917 (citing Tex. Tax Code Ann. §§ 41 .01– 6 Brennan and Smith paid the assessed back taxes, plus penalties and interest, in September 2012. 7 Section 42.09 provides, in part, that “procedures prescribed by this title for adjudication of the grounds of protest authorized by this title are exclusive.” Tex. Tax Code Ann. § 42.09 (a) (West 2015). 8 .71,8 42.09 (West 2015 & Supp. 2015) (outlining the administrative protest procedure available to a property owner to challenge valuation of his property by an appraisal district); Webb Cty.

11
George Wood v. Marti Kennedy and Doyle Murphree, Jr., Indvidually as as Temporary Co-Administrators of the Estate of Doyle Murphree, St.green
texapp · 2014 · cited in 1 Texas opinions naming this issue, 2016–2016
1 sentence

2016See Wood v. Kennedy, 473 S.W.3d 329 , 336–37 (Tex. App.—Houston [14th Dist.] 2014, no pet.).

11
Houston Health Clubs, Inc. v. First Court of Appealsgreen
tex · 1986 · cited in 1 Texas opinions naming this issue, 2007–2007
1 sentence

2007Ann. art. 59.01(2) (Vernon 2006). 3: Vafaiyan appeared pro se with S. Price Smith, an attorney, acting as his co-counsel. 4: See id. art. 59.02(e) (providing that, after notice to the property owner and a hearing, the trial court “may make appropriate orders to preserve and maintain the value of the property until a final disposition [of the forfeiture proceeding], including the sale of the property if that is the only method by which the value of the property may be preserved until final disposition”). 5: Id. art. 59.05(a). 6: Houston Health Clubs, Inc. v. First Court of Appeals, 722 S.W.2d 6

11
McCullough v. Producers Gas Co.green
texapp · 1981 · cited in 1 Texas opinions naming this issue, 1993–1993
1 sentence

1993See McCullough v. Producers Gas Co., 616 S.W.2d 702 (Tex.Civ.App.—Waco 1981, writ ref'd n.r.e.) (suggesting the need for a motion for allowance of the expenses in question).

11

Distinguished, questioned or overruled (1)

CaseNegativeCited
Russell D. Miller and Juliet Investments, Inc. v. Darlene Argumaniz, Individually and on Behalf of Argmil, Inc.green
texapp · 2015 · cited in 1 Texas opinions naming this issue, 2020–2020
1 sentence

2020See Bustamante, 529 S.W.3d at 462 ; Justiss, 397 S.W.3d at 156 ; but cf. Miller v. Argumaniz, 479 S.W.3d 306 , 312–13 (Tex. App.—El Paso 2015, pet. denied) (holding that a four-year-old appraisal sufficed to provide a factual basis for the valuation testimony pursuant to Rule 701 and the property owner rule); Long Island Village Owners Ass'n v. Berry, No. 13-14-00363-CV, 2016 WL 1072856 , at *15 (Tex. App.—Corpus Christi–Edinburg Mar. 17, 2016, pet. denied) (mem. op.) (approving property owner valuation supported by the original purchase price and the most recent tax statement); RWH Homebuilde

11

Also cited on this issue (7)

CaseCitedYears
SMILES v. State green
texapp · 2009
2 sentences

2015See Sullivan, 701 S.W.2d at 909 ; Smiles, 298 S.W.3d at 719 . 8 The evidence is legally sufficient.

2015See Sullivan, 701 S.W.2d at 909 ; Smiles, 298 S.W.3d at 719 . 8 The evidence is legally sufficient.

32015–2015
Rebeca D. Balderas-Ramirez v. Anthony CarlDP green
texapp · 2017
1 sentence

2026Id. at 157; Balderas-Ramirez v. Felder, 537 S.W.3d 625, 632–33 (Tex. App.—Austin 2017, pet. denied) (noting that issue of market value of owner’s property is one on which expert testimony would otherwise be required).

12026–2026
Bullock, Henry Richard Jr. A/K/A Imari Abybakari green
texapp · 2015
1 sentence

2023See Sullivan, 701 S.W.2d at 909 ; Smiles [v. State], 298 S.W.3d [716,] 719 [(Tex. App.— Houston [14th Dist.] 2009, no pet.)]. 9 Bullock, 479 S.W.3d at 427–28.

12023–2023
Harris County Appraisal Review Board v. General Electric Corp. green
texapp · 1991
2 sentences

2004We note that, in reaching its holding, the Fina, court did not address section 41.44(c), or any other authority, concerning the timeliness of a property owner’s protest in the absence of a statutorily required notice, and we decline to follow its reasoning. 23 In Harris County Appraisal Review Board v. General Electric Corp., an appraisal review board appealed from a trial court’s rendition of summary judgment in favor of a property owner on its claim that, after the property owner had timely paid its property taxes and filed a protest of the appraised value of the subject property, *157 the b

2004We note that, in reaching its holding, the Fina, court did not address section 41.44(c), or any other authority, concerning the timeliness of a property owner’s protest in the absence of a statutorily required notice, and we decline to follow its reasoning. 23 In Harris County Appraisal Review Board v. General Electric Corp., an appraisal review board appealed from a trial court’s rendition of summary judgment in favor of a property owner on its claim that, after the property owner had timely paid its property taxes and filed a protest of the appraised value of the subject property, *157 the b

12004–2004
City of Houston v. Fore green
tex · 1967
1 sentence

1997You suggest that the case of City of Houston v. Fore , 412 S.W.2d 35 (Tex. 1967), stands for the proposition that due process requires the disclosure to referendum voters of "the method and rate of taxation." In that case, the city failed to notify a property owner of a hearing at which he could have challenged certain street paving assessments.

11997–1997
Ruckelshaus v. Monsanto Co. green
scotus · 1984
1 sentence

1993Id.

11993–1993
Texas Architectural Aggregate, Inc. v. Adams green
texapp · 1985
1 sentence

1985Texas Architectural Aggregate v. Adams, supra. Here, as in Adams , the property owner does not challenge the constitutionality of § 42.09 in making exclusive the remedies provided by the Code.

11985–1985

Statutes the citing opinions construe

TX § Tex. Tax Code § 41.41 (6) TX § Tex. Tax Code § 42.09 (6) TX § Tex. Penal Code § 31.03 (4) TX § Tex. Penal Code § 31.08 (4) TX § Tex. Tax Code § 1.04 (4) TX § Tex. Tax Code § 11.43 (4) TX § Tex. Tax Code § 25.21 (4) TX § Tex. Tax Code § 25.23 (4) TX § Tex. Penal Code § 15.01 (3) TX § Tex. Tax Code § 25.02 (3) TX § Tex. Tax Code § 41.411 (3) TX § Tex. Tax Code § 6.24 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 37 (1985–2026) PA 23 (1974–2024) CA 13 (1994–2025) IL 9 (1989–2018) NY 7 (1927–2016) MI 6 (1978–2025) OH 6 (2001–2024) LA 6 (1970–2013) SD 5 (1979–2013) CT 5 (1982–2014) IN 4 (1901–2023) GA 4 (1910–2000) WI 4 (1987–2023) NJ 3 (2009–2019) IA 3 (2019–2024) WA 2 (1933–1990) KY 2 (1939–1990) NM 2 (1998–2001) AL 2 (2000–2012) FL 2 (1975–1990) MN 2 (2011–2018) OK 2 (1958–2002) AK 2 (2023–2024)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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