West Hardin County Consolidated Independent School District v. Wallace Maury Poole d/b/a L&B Production

Summary

The Supreme Court of Texas held that Wallace Maury Poole's allegations concerning costs incurred after a school district foreclosed on an oil and gas lease did not constitute a takings claim for which governmental immunity was waived under the Texas Constitution. The Court also rejected the characterization of the action as a collateral attack on the prior tax judgment. It reversed the court of appeals and rendered judgment dismissing the case.

Holdings

1. Poole's allegations asserted that the District injured him through its conduct, not that the District took his property without compensation; therefore, the allegations did not state a takings claim for which governmental immunity from suit was waived.
2. The trial court correctly dismissed Poole's case for want of jurisdiction.

Questions Presented

1. Whether Poole's claim for damages allegedly caused by the District's post-foreclosure conduct constituted a takings claim for which governmental immunity from suit was waived under article I, section 17 of the Texas Constitution.
2. Whether the trial court correctly dismissed Poole's action for want of jurisdiction.

Disposition

reversed