Central Appraisal District of Taylor County v. Western AH 406, Ltd., 372 S.W.3d 672

This is a property tax dispute over Quail Hollow, a 406-unit apartment complex in Abilene, TX.
Western AH 406, Ltd. challenged Taylor County CAD’s 2002–2004 appraisals; trial court ruled for TCAD.
On Western’s appeal, we reversed and remanded for a new trial in Western I (Western I).
On remand, experts Teel and Scoggins issued retrospective value opinions for 2002–2008; Scoggins also offered an option including favorable financing.
TCAD challenged the experts under Daubert/Robinson; court held Teel’s methods were unreliable and excluded his testimony; reverse and remand for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are Teel’s value opinions reliable evidence?	Teel appropriately incorporated rent/occupancy restrictions as “individual characteristics.”	Teel misinterpreted Lockbox, overstated restrictions, and misapplied financing terms.	Unreliable; Teel’s testimony excluded; no evidence support.
Is Little’s review testimony admissible to bolster Teel?	Little’s review confirms Teel’s methodologies.	Little merely corroborates flawed conclusions.	Unreliable foundation vitiates admissibility; Little’s testimony likewise inadmissible.
Did the trial court err in denying JNOV/new trial based on the evidence?	There is some evidence of market value without Teel’s restrictive deductions.	No-evidence standard failed; JNOV/new trial appropriate.	Remand for further proceedings; JNOV/new trial error sustained to extent challenged.
Should TCAD’s attorney’s fees award be affirmed?	Trial court correctly awarded fees under §42.29.	Judgment reversed; fees should be reversed.	Reversed; attorney’s fees remanded for further proceedings.

Whirlpool Corp. v. Camacho, 298 S.W.3d 631 (Tex. 2009) (gatekeeping and reliability standard for expert testimony; no abuse of discretion if reliable at each step)
Havner v. E.B. Taylor, 953 S.W.2d 714 (Tex. 1998) (unreliable expert testimony is legally no evidence)
Weingarten Realty Investors v. Harris Cnty. Appraisal Dist., 93 S.W.3d 280 (Tex. App.—Hou. [14th Dist.] 2002) (no-evidence standard; reliability review of expert testimony)
Gammill v. Jack Williams Chevrolet, Inc., 972 S.W.2d 713 (Tex. 1998) (reliability and evidentiary sufficiency for expert testimony; analytical gap standard)
City of Keller v. Wilson, 168 S.W.3d 802 (Tex. 2005) (no-abuse-of-discretion default; standard for appellate review of fact findings)