Texas Disposal Systems Landfill, Inc. v. Travis Central Appraisal District, by and Through Marya Crigler, Acting in Her Official Capacity as Chief Appraiser of Travis Central Appraisal District, 694 S.W.3d 752

Texas Disposal Systems Landfill (TDS Landfill) challenged a property tax appraisal by the Travis Central Appraisal District (Travis CAD), protesting only on the ground that the appraisal was not "equal and uniform."
The Appraisal Review Board (ARB) agreed with TDS Landfill and issued an order adjusting the value based on equal and uniform grounds.
The chief appraiser, acting for Travis CAD, sought to appeal the ARB's order in district court, arguing that the appraised value also failed to reflect market value.
The dispute centers on whether the district court can hear arguments on grounds not raised in the property owner's original protest before the ARB.
Both parties and many amici agreed the relevant Tax Code provisions limited the court's authority and that the limits were jurisdictional.
The trial and appellate courts differed on whether the district court's review was jurisdictionally limited to the specific grounds raised in the owner's protest.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are Tax Code limits on appeals jurisdictional?	Yes: Limits the district court's power.	Yes: Defines right to appeal/subject matter.	No: Limits are not jurisdictional, but statutory.
Can chief appraiser appeal on grounds not protested?	No: Only grounds raised may be challenged.	Yes: District court reviews the ARB order.	No: Review is limited to grounds owner protested.
Trial court's scope in reviewing ARB's order	Review is limited to protested grounds.	Should review all issues in pleadings.	Court is limited to protested grounds, but takes evidence.
Constitutionality of limiting appraised value review	Not central to arguments presented.	Must ensure value is both equal/uniform & FMV.	Any appraised value must satisfy constitutional mandates.

Cameron Appraisal Dist. v. Rourk, 194 S.W.3d 501 (Tex. 2006) (ARB has exclusive, original jurisdiction over property value protests)
Houston Mun. Emps. Pension Sys. v. Ferrell, 248 S.W.3d 151 (Tex. 2007) (Judicial review of administrative orders is strictly statutory)
In re Nestle USA, Inc., 387 S.W.3d 610 (Tex. 2012) (Equal and uniform property tax requires tax to be in proportion to value)
Enron Corp. v. Spring Indep. Sch. Dist., 922 S.W.2d 931 (Tex. 1996) (Market value appraisals must not be unreasonable, arbitrary, or capricious)
Willacy Cnty. Appraisal Dist. v. Sebastian Cotton & Grain, Ltd., 555 S.W.3d 29 (Tex. 2018) (Trial de novo in district court is not limited to administrative record)