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Reddy Partnership/5900 North Freeway Lp and v. Harris County Appraisal District, Respondent

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In this ad valorem property tax case, we decide whether a plaintiff’s trivial misnomer in its petition for judicial review defeats a trial court’s jurisdiction. Because we conclude that it does not, we grant the petition for review, reverse the court of appeals’ judgment, and remand the case to the trial court for further proceedings.

The property is located at 5900 North Freeway, in Houston. On June 21, 2002, Reddy Partnership, a Texas general partnership, sold it to Reddy Partnership/5900 North Freeway, L.P., a Texas limited partnership. On April 28, 2008, Harris County Appraisal District (HCAD) mailed a Notice of Appraised Value of the property to “Reddy Partnership, ETAL [sic].” A notice of protest was subsequently filed with HCAD under the same name, contesting the 2008 tax assessment. After a hearing, HCAD’s Appraisal Review Board rejected the protest. The Board’s order, addressed to “Reddy Partnership, ETAL,” was mailed to the partnership’s designated agent, O’Connor & Associates.

On September 11, 2008, “Reddy Partnership ETAL, as the property owners, [sic]” timely filed a petition for judicial review challenging the Board’s determination. Fifteen months later, after the 45-day statute of limitations to appeal the Board’s order had passed, HCAD filed a plea to the jurisdiction, contending that the trial court lacked subject matter jurisdiction over the petition because the plaintiff, “ Reddy Partnership,” was not the owner of the property on January 1, 2008, and, therefore, lacked standing to seek judicial review of the Board’s order.*fn1 In support of its plea, HCAD attached a copy of the warranty deed in which Reddy Partnership sold the property to Reddy Partnership/5900 North Freeway, L.P.

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