Unreported / Non-Citable
Background
Sadeghian and related entities owned or held interests in multiple properties in Denton County, Texas. After the Denton County Appraisal Review Board (ARB) issued orders on the disputed 2023 and 2024 tax year appraisals around August 14, 2024, Sadeghian filed an original petition for judicial review on October 14, 2024, within the statutory 60-day deadline.
However, the original petition identified the properties only through a hyperlink to a Dropbox document titled “Order-of-Determination-of-Protest-2024-Tax-Year-Denton.” The petition stated the properties were “fully described, documented and attached to this Petition as a Drop Box Link” but contained no other property descriptions in the pleading itself. After receiving emails from DCAD’s counsel questioning whether the petition adequately identified properties, Sadeghian filed a first amended petition in April 2025 and a second amended petition on July 31, 2025, which included approximately 514 ARB orders as exhibits.
DCAD filed a plea to the jurisdiction arguing the petition never properly identified the properties and that the second amended petition improperly introduced property identifications more than nine months after the 60-day statutory deadline. The trial court granted the plea and dismissed for lack of jurisdiction.
The Court’s Holding
The Texas Court of Appeals affirmed the trial court’s dismissal. The court held that the original petition failed to satisfy the jurisdictional requirement of Texas Tax Code § 42.21(h), which mandates that a petition for judicial review contain “sufficient information to identify the property that is the subject of the appeal.” A hyperlink to external documents cannot satisfy this requirement because: (1) hyperlinks can be altered or changed at any time, making verification of authenticity and integrity impossible; and (2) a hyperlink does not comply with Texas Rule of Civil Procedure 59, which requires that instruments be attached to, filed with, or copied directly into the body of the pleading.
The court reasoned that allowing hyperlinks would effectively erase the statutory requirement that petitions describe the property, violating the basic principle of statutory construction that every word must be given effect. The court distinguished between inadequate property descriptions (which can be corrected through special exceptions and amendments) and complete absence of property description. Here, the original petition contained no actual property identification—only a link—so § 42.21(h) was never triggered and jurisdiction was never acquired. Because jurisdiction was not established when the original petition was filed, the second amended petition filed nine months later could not relate back to cure the defect.
The court also held that Sadeghian’s claims regarding 2023 tax year properties were untimely. Each tax year constitutes a separate and discrete appeal, requiring separate adherence to the 60-day deadline. Since the original petition mentioned only the 2024 tax year and 2023 claims first appeared in the second amended petition (filed nearly a year after the orders were received), those claims fell outside the jurisdictional deadline.
Key Takeaways
- Petitions for judicial review in property tax appeals must identify properties with specificity within the body of the pleading, not via external hyperlinks or references to outside documents.
- Hyperlinks to Dropbox, cloud storage, or similar services are jurisdictionally insufficient and do not comply with Texas procedural rules requiring exhibits be attached or copied into the pleading.
- The 60-day filing deadline in § 42.21(a) is jurisdictional. Once missed, it cannot be salvaged by later amendments, and amended petitions cannot relate back if jurisdiction was never acquired.
- Each tax year constitutes a separate appeal with its own 60-day deadline. Practitioners must ensure all relevant tax years are addressed in the timely original petition.
Why It Matters
This decision provides critical guidance for property tax practitioners representing taxpayers in appraisal disputes. The strict requirement that properties be identified within the pleading itself—not through external links—reflects the court’s concern about authenticity, integrity, and compliance with civil procedure rules. Practitioners must ensure that original petitions include complete, specific property descriptions directly in the pleading to avoid dismissal on jurisdictional grounds.
The decision also reinforces that jurisdictional defects in tax appeals cannot be cured by consent, waiver, estoppel, or later amendments. The 60-day deadline is not merely procedural but jurisdictional, and failure to meet it bars the appeal entirely. Property owners seeking to challenge multiple years of valuations must file timely petitions addressing all relevant tax years separately, or face losing appeals for years not mentioned in the original petition.