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City of Laredo v. SOUTH TEXAS NAT. BANK

Citations: 775 S.W.2d 729; 1989 Tex. App. LEXIS 2420; 1989 WL 107281Docket: 04-88-00225-CV

Court: Court of Appeals of Texas; July 12, 1989; Texas; State Appellate Court

Narrative Opinion Summary

In this case, the City of Laredo brought an action against several banks to recover delinquent ad valorem taxes on bank shares. The banks counterclaimed, asserting the taxes were illegally assessed. The trial court ruled in favor of the banks, granting summary judgment and awarding attorney fees, prompting the City to appeal. The appellate court addressed several key issues: it ruled that the payments by the banks were not voluntary, thus allowing for their recovery; it found that the statute of limitations for the 1980 taxes was tolled by earlier pleadings; and it determined that the awarded attorney fees exceeded statutory limits, requiring modification. The court also addressed procedural issues regarding expert witness designation and the trial court's directive on tax reassessment methods. The appellate court modified the trial court's judgment by removing the directive on tax reassessment, deleting the excessive attorney fees, and confirming the City's ability to reassess 1980 taxes. The case was remanded for further proceedings on specific issues, while affirming other aspects of the trial court's judgment.

Legal Issues Addressed

Award of Attorney Fees

Application: The court found the award of attorney fees to the Banks was improper as it exceeded statutory limits set forth in the Property Tax Code, indicating legislative intent to limit such awards.

Reasoning: The award of attorney fees exceeding these limits was deemed improper, and point of error seven is sustained.

Expert Witness Designation

Application: The court sustained the exclusion of Arthur Volpe's testimony as the Banks failed to designate him as an expert witness in pre-trial interrogatories and did not show good cause for his inclusion.

Reasoning: Consequently, the court ruled to exclude Volpe's testimony, sustaining points of error eight and nine.

Reassessment of Taxes

Application: The court ruled that the trial court overstepped its bounds by specifying the method for tax reassessment, affirming the right of taxing agencies to reassess in accordance with applicable laws.

Reasoning: The court found that the trial court had overstepped its bounds in specifying the reassessment process and sustained these points of error as well.

Statute of Limitations and Cross-Action

Application: The Laredo National Bank was not initially named in the City's suit but filed a cross-action, and the court found that the earlier pleadings provided sufficient notice to toll the statute of limitations.

Reasoning: A petition must only provide notice of the cause of action for limitations to be tolled, which Laredo National Bank's earlier pleadings accomplished.

Voluntary Payment Doctrine

Application: The court determined that the payments made by the Banks were not voluntary since the City did not use the funds and maintained them in a deferred revenue account pending litigation.

Reasoning: Consequently, the payments made by Banks were not deemed voluntary.