Texas Court of Appeals, 15th District, 2025

City of Coppell, Texas, the City of Humble, Texas, the City of DeSoto, Texas, the City of Carrollton, Texas, and the City of Farmers Branch, Texas v. Glenn Hegar, in His Official Capacity as Texas Comptroller of Public Accounts

City of Coppell, Texas, the City of Humble, Texas, the City of DeSoto, Texas, the City of Carrollton, Texas, and the City of Farmers Branch, Texas v. Glenn Hegar, in His Official Capacity as Texas Comptroller of Public Accounts
Texas Court of Appeals, 15th District · Decided March 3, 2025
City of Coppell, Texas, the City of Humble, Texas, the City of DeSoto, Texas, the City of Carrollton, Texas, and the City of Farmers Branch, Texas v. Glenn Hegar, in His Official Capacity as Texas Comptroller of Public Accounts

Opinion

3/3/2025 6:54 PM Velva L. Price District Clerk Travis County CAUSE NO. D-1-GN-21-003198* D-1-GN-21-003198 Victoria Benavides (Consolidated with D-1-GN-21-003203) FILED IN CITY OF COPPELL, TEXAS; CITY OF § IN THE DISTRICT 15thCCOURT OURT OOF F APPEALS HUMBLE, TEXAS; CITY OF DESOTO, § AUSTIN, TEXAS TEXAS; CITY OF CARROLLTON, TEXAS; § 3/4/2025 9:06:20 AM CITY OF FARMERS BRANCH, TEXAS; § CHRISTOPHER A. PRINE Clerk CITY OF ROUND ROCK, TEXAS § § Plaintiffs, § § TRAVIS COUNTY, TEXAS § VS. § § § GLENN HEGAR, IN HIS OFFICIAL § CAPACITY AS TEXAS COMPTROLLER OF § PUBLIC ACCOUNTS, § 201ST JUDICIAL DISTRICT § Defendant.

COPPELL PLAINTIFFS’ NOTICE OF APPEAL The City of Coppell, Texas, the City of Humble, Texas, the City of DeSoto, Texas, the City of Carrollton, Texas, and the City of Farmers Branch, Texas (“Coppell Plaintiffs”) appeal the Final Judgment signed on December 3, 2024, addressing whether rules adopted by the Comptroller of Public Accounts for allocation of local sales tax contravene the Tax Code. The trial court, trial court case number, and style of this matter are shown in the above caption.

Even though the Coppell Plaintiffs believe they received all the relief necessary to declare that the rules they challenged contravene the Tax Code, the Coppell Plaintiffs file this notice because counsel for the Comptroller of Public Accounts insists that the Coppell Plaintiffs did not receive that relief and has advised that the Comptroller of Public Accounts intends to propose rules in response to the December 3, 2024, judgment that the

COPPELL PLAINTIFFS’ NOTICE OF APPEAL—PAGE 1 Coppell Plaintiffs believe would directly contravene their understanding of that judgment. Because of that conflict, the first issue in this appeal will be a determination of the meaning of the judgment, either by the Court of Appeals or by this Court on remand from the Court of Appeals, although the judge that signed the judgment is no longer a district court judge. Depending on the resolution of that issue, the Court of Appeals may also need to address whether this Court correctly interpreted the statutory provisions governing the rules at issue in the appeal.

In accordance with Texas Rule of Appellate Procedure 25.1(d)(9), the Coppell Plaintiffs state that this matter is “brought by or against the state or a board, commission, department, office, or other agency in the executive branch of the state government, including a university system or institution of higher education.” TEX. R. APP. P. 25.1(d)(9)(A). Therefore, this appeal is taken to the Court of Appeals for the Fifteenth District of Texas.

As required by Texas Rule of Appellate Procedure 25.1(e) and Texas Civil Practice and Remedies Code § 51.017(a), a copy of this notice of appeal is being served on the court reporter as reflected in the certificate of service below.

COPPELL PLAINTIFFS’ NOTICE OF APPEAL—PAGE 2 HOLLAND & KNIGHT LLP By: /s/ James B. Harris James B. Harris State Bar No. 09065400 Stephen F. Fink State Bar No. 07013500 Richard B. Phillips, Jr. State Bar No. 24032833 Reed C. Randel State Bar No. 24075780 1722 Routh Street, Suite 1500 Dallas, Texas 75201 Telephone: 214.969.1700 Fax: 214.969.1751 E-mail: [email protected] E-mail: [email protected] Email: [email protected] E-mail: [email protected] Brandon L. King State Bar No. 24100613 San Jacinto Boulevard, Suite 1900 Austin, Texas 78701 Telephone: 512.469.6126 Fax: 512.482.5009 E-mail: [email protected]

COPPELL PLAINTIFFS’ NOTICE OF APPEAL—PAGE 3 CERTIFICATE OF SERVICE The undersigned certifies that on March 3, 2025, a true and correct copy of the foregoing document has been served pursuant to the Texas Rules of Civil Procedure upon all counsel of record by eservice and on the court reporter at the email address shown below: Jamie K. Foley Official Court Reporter 250th Judicial District Court 1700 Guadalupe, 9th Floor Austin, TX 78701 [email protected]

By: /s/ James B. Harris James B. Harris

COPPELL PLAINTIFFS’ NOTICE OF APPEAL—PAGE 4 Automated Certificate of eService This automated certificate of service was created by the efiling system.

The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.

Richard Phillips on behalf of Richard Phillips Jr. Bar No. 24032833 [email protected] Envelope ID: 98014525 Filing Code Description: Notice of Appeal Filing Description: COPPELL PLAINTIFFS’ NOTICE OF APPEAL Status as of 3/4/2025 8:31 AM CST Associated Case Party: CITY OF COPPELL TEXAS Name BarNumber Email TimestampSubmitted Status Reed C.Randel [email protected] 3/3/2025 6:54:56 PM SENT Brandon L.King [email protected] 3/3/2025 6:54:56 PM SENT James B.Harris [email protected] 3/3/2025 6:54:56 PM SENT Richard Phillips 24032833 [email protected] 3/3/2025 6:54:56 PM SENT

Associated Case Party: GLENN HEGAR TEXAS STATE COMPTROLLER OF PUBLIC ACCOUNTS Name BarNumber Email TimestampSubmitted Status Ray Langenberg [email protected] 3/3/2025 6:54:56 PM SENT Kyle PierceCounce [email protected] 3/3/2025 6:54:56 PM SENT

Case Contacts Name BarNumber Email TimestampSubmitted Status Denise Putnam [email protected] 3/3/2025 6:54:56 PM SENT Steve Sheets [email protected] 3/3/2025 6:54:56 PM SENT Cindy Bourland [email protected] 3/3/2025 6:54:56 PM SENT Doug Sigel [email protected] 3/3/2025 6:54:56 PM SENT Sinead O'Carroll [email protected] 3/3/2025 6:54:56 PM SENT Joyce Goodman [email protected] 3/3/2025 6:54:56 PM SENT Susan Farris [email protected] 3/3/2025 6:54:56 PM SENT Bryan Dotson [email protected] 3/3/2025 6:54:56 PM SENT Sherri Rodgers [email protected] 3/3/2025 6:54:56 PM SENT

Case-law data current through December 31, 2025. Source: CourtListener bulk data.