L.T. Runels, Jr. v. Tax Loans USA, Ltd., 07-24-00246-CV

Runels and his siblings inherited real property in Lubbock, Texas, encumbered by a tax lien due to unpaid property taxes.
One sibling, Tony, used Tex. Tax Code § 32.06(a-1) to obtain a loan from Tax Loans USA, Ltd. (USA) to pay the tax debt, resulting in USA acquiring the tax lien from the county.
Tony made payments on the loan but died before satisfying the debt; USA sought to foreclose on the lien.
Only Runels contested the foreclosure; both parties moved for summary judgment, and the trial court initially ruled for USA.
On appeal, the court previously found a material fact issue precluded summary judgment for USA, remanded, and the trial court again granted summary judgment to USA; Runels appealed once more.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Legality of contract under § 32.06	All co-owners must join for the lien and contract to be valid	One co-owner can use § 32.06 to pay lien	Tony could contract with USA for his share, not for all
Enforceability of lien against entire property	Lien is void if not all owners consented	Lien valid to extent of participating owner's share	USA can only enforce lien on Tony's undivided interest
Recovery of excess foreclosure proceeds	Runels entitled to proceeds exceeding the tax debt	Not directly addressed	Runels did not move for summary judgment on this—denied
Constitutionality of § 32.06	Statute unconstitutional	Not directly addressed	Issue waived—was not raised in trial court

Trimble v. Farmer, 305 S.W.2d 157 (Tex. 1957) (owner can only authorize transfer of tax lien to the extent of property they own; lien not enforceable against interests of non-consenting co-owners)