City of Dallas v. Tci West End, Inc., 463 S.W.3d 53

City of Dallas sued TCI West End, Inc. for demolishing a building in a historic overlay district in violation of city ordinances governing contributing structures and demolition procedures.
City sought civil penalties under Texas Local Government Code ch. 54, subchapter B (§ 54.012 authorizes certain municipal enforcement actions; § 54.017 authorizes civil penalties subject to proof of actual notice and subsequent noncompliance).
Jury found for the City; trial court awarded $750,000 in civil penalties.
Court of appeals reversed, holding subchapter B only applies to health-and-safety ordinances (not general land‑use zoning) and alternatively finding insufficient evidence of actual notice before the demolition.
Texas Supreme Court granted review, held de novo that § 54.012(3) unambiguously authorizes civil actions to enforce zoning ordinances that regulate land use, and remanded to address the alternative notice/merits issue.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Scope of § 54.012(3): whether subchapter B is limited to health-and-safety ordinances	§ 54.012(3) plainly authorizes municipalities to enforce zoning ordinances regulating land use, including historic‑district rules	Subchapter B is titled "Municipal Health and Safety Ordinances" and other subsections reference health/safety, so it should be confined to those matters	Court: § 54.012(3)’s plain text includes zoning regulating land use; imposing a health/safety limitation contradicts the statute and would render language in other subsections superfluous; reverse court of appeals on this point
§ 54.017 actual‑notice requirement: whether civil penalties require notice before the violation	City: § 54.017 provides two alternatives (actual notice + violation OR actual notice + failure to take action necessary for compliance); penalties may be sustained on the latter ground even if notice occurred after demolition if post‑violation compliance steps were possible	TCI: If demolition already occurred, compliance afterward was impossible because approval from Landmark Commission would have been required prior to demolition	Court: The court of appeals erred by not considering the alternative statutory ground (failure to take action necessary for compliance after notice); remanded for further proceedings to address this issue

City of Rockwall v. Hughes, 246 S.W.3d 621 (Tex. 2008) (standards for de novo statutory interpretation)
TGS-NOPEC Geophysical Co. v. Combs, 340 S.W.3d 432 (Tex. 2011) (presume Legislature chose words with care; consider statute as whole)
Crosstex Energy Servs., L.P. v. Pro Plus, Inc., 430 S.W.3d 384 (Tex. 2014) (avoid interpretations that render statutory language meaningless)
Waffle House, Inc. v. Williams, 313 S.W.3d 796 (Tex. 2010) (statutory headings do not limit or expand statutory meaning)
Hollingsworth v. City of Dallas, 931 S.W.2d 699 (Tex. App.—Dallas 1996) (addressing interplay of ch. 54 and ch. 211 remedies)
City of Lorena v. BMTP Holdings, L.P., 409 S.W.3d 634 (Tex. 2013) (use of disjunctive "or" creates alternative statutory bases)