Case Information
*0 FILED IN 15th COURT OF APPEALS AUSTIN, TEXAS 6/27/2025 2:21:55 PM CHRISTOPHER A. PRINE Clerk
*1 ACCEPTED 15-25-00112-CV Challenge to Constitutionality of a State Statute Print FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS This form must be completed by a party filing a petition, motion or other pleading challenging the 6/27/2025 2:21 PM constitutionality of a state statute . The completed form must be filed with the court in which the cause is CHRISTOPHER A. PRINE pending as required by Section 402.010 (a-1), Texas Government Code. CLERK 15-25-00112-CV Cause Numbe r ( (cid:44)(cid:73)(cid:3)(cid:46)(cid:81)(cid:82)(cid:90)(cid:81) ): Court ( (cid:44)(cid:73)(cid:3)(cid:46)(cid:81)(cid:82)(cid:90)(cid:81) ): Texas 15th Court of Appeals Styled : Pecos Housing Finance Corporation et al v. City of Haltom City, Texas
(e.g., John Smith v. All American Insurance Co.; in re Mary Ann Jones; In the Matter of the Estate of George Jackson) Contact information for party* challenging the constitutionality of a state statute. (* If party is not a person, provide contact information for party, party's representative or attorney.) Name: Telephone:
City of Haltom City (817) 222-7700 Address: Fax: 4801 Haltom Road City/State/Zip: State Bar No. (if applicable): Haltom City, Texas 76117 Email: Person completing this form is: Attorney for Party Unrepresented Party Other : Counsel for Appellant ✔ Identify the type of pleading you have filed challenging the constitutionality of a state statute . Petition Answer Motion (Specify type) : ✔ Other : Is the Attorney General of the State of Texas a party to or counsel in this cause? Yes ✔ No List the state statute(s) being challenged in your pleading and provide a summary of the basis for your challenge . ( Additional pages may be attached if necessary. )
Appellee, Haltom City, has alleged that Appellant's actions, which were authorized by Tex. Loc. Gov't Code Sec. 394.001 et seq., "violate the Texas Constitution's rules against extra-jurisdictional taxation by seeking to impose a system of taxation on properties located outside the boundaries of Reeves County where Pecos City is located." See Plaintiff's First Amended Petition and Application for Temporary Restraining Order and Injunctive Relief , at 14-15. Appellee further alleges that "[i]f [Tex. Loc. Gov't Code Sec. 394.903] could be read to empower Pecos HFC to take properties outside of Reeves County off the tax rolls of other counties, this would violate the Texas Constitution's limits on the scope of Texas counties' taxing authority." Id. at 15; see also Plaintiff's First Amended Application for Temporary Injunction and Response to Defendants' Plea to the Jurisdiction , at 12 (same).
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