City of Ingleside, Texas v. City of Corpus Christi, Texas

469 S.W.3d 589 (Tex. 2015) · Supreme Court of Texas · July 27, 2015 · No. No. 14-0548

Summary

The Supreme Court of Texas considered whether a declaratory-judgment action concerning the meaning of a municipal ordinance defining a city boundary by reference to the shoreline presented a nonjusticiable political question. The Court held that interpreting whether piers, wharves, docks, and similar structures fall within the shoreline boundary is a judicially manageable issue distinct from legislatively establishing or altering a municipal boundary. The Court reversed the court of appeals and remanded for consideration of the respondent’s remaining jurisdictional challenges.

Holdings

  1. The action did not present a nonjusticiable political question. Ingleside sought interpretation and application of existing boundary ordinances, not judicial alteration or selection of the municipal boundary.
  2. The dispute over whether the shoreline may be reshaped by natural or artificial fixtures was justiciable because it involved interpretation of an ordinance and application of existing legal standards, rather than a legislative determination of where the boundary should be.

Questions Presented

  1. Whether Ingleside's declaratory-judgment action presented a nonjusticiable political question because it concerned the boundary between two home-rule municipalities.
  2. Whether determining whether the shoreline boundary includes or excludes natural or artificial protrusions from the fast land is a judicially manageable issue.
  3. Whether the court of appeals properly dismissed the action for lack of subject-matter jurisdiction rather than allowing the trial court to address the remaining jurisdictional challenges.

Disposition

reversed_and_remanded

Cases Cited (20)

  • Bland Indep. Sch. Dist. v. Blue, 34 S.W.3d 547, 554 (Tex. 2000)(followed)
  • Tex. Natural Res. Conservation Comm'n v. IT-Davy, 74 S.W.3d 849, 855 (Tex. 2002)(followed)
  • Tex. Dep't of Parks & Wildlife v. Miranda, 133 S.W.3d 217, 226 (Tex. 2004)(followed)
  • Alexander Oil Co. v. City of Seguin, 825 S.W.2d 434, 436 n.3 (Tex. 1991)(distinguished)
  • City of Wichita Falls v. State ex rel. Vogtsberger, 533 S.W.2d 927, 929 (Tex. 1976)(distinguished)
  • Tex. Ass'n of Bus. v. Tex. Air Control Bd., 852 S.W.2d 440, 444 (Tex. 1993)(followed)
  • State ex rel. Pan Am. Prod. v. Texas City, 303 S.W.2d 780, 782 (Tex. 1957)(distinguished)
  • City of Waco v. City of McGregor, 523 S.W.2d 649, 654 (Tex. 1975)(distinguished)
  • Neeley v. W. Orange-Cove Consol. Indep. Sch. Dist., 176 S.W.3d 746, 777-78, 780 & n.180 (Tex. 2005)(followed)
  • Edgewood Indep. Sch. Dist. v. Kirby, 777 S.W.2d 391, 394 (Tex. 1989)(followed)

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