Texas courts exist to enforce the Constitution — not administrative convenience.

Texas Supreme Court, Fair Valuations, and the Constitutional Question

Why This Matters

The Texas Supreme Court has made something unmistakably clear: property taxation in Texas must be equal, uniform, and constitutional — and unconstitutional appraisal methods do not become lawful simply because a taxpayer once accepted them.

This principle matters not only to homeowners and small business owners, but to the integrity of the Texas Constitution itself.

For years, appraisal districts and appraisal review boards (ARBs) have relied on a quiet assumption — that if a taxpayer paid in prior years or did not protest aggressively enough, the government could continue using flawed appraisal methods without consequence. The Texas Supreme Court has rejected that idea.

What the Texas Supreme Court Has Reaffirmed

In a line of cases addressing property taxation and constitutional limits, the Court has reaffirmed a core rule:

Appraisal methods that violate the Texas Constitution’s “equal and uniform” requirement are unconstitutional — even if the taxpayer previously accepted or paid earlier valuations.

This is not about disagreeing with a number.

This is about challenging a process.

Uniformity violations are structural constitutional defects, not waivable personal choices.

The Constitutional Standard

Article VIII, Section 1 of the Texas Constitution requires that:

• Taxation be equal and uniform

• Similar properties be appraised using consistent and lawful methods

• Government actors stay within the authority granted to them

When appraisal systems abandon those requirements — whether through burden-shifting, policy shortcuts, or distorted valuation models — they cross from discretion into unconstitutional action.

The Question Texas Courts Must Answer

This leads to the central constitutional question that deserves judicial review:

Did the Appraisal Review Board and Collin County violate the Texas Constitution by applying an unconstitutional appraisal methodology — after the State failed to meet its constitutional obligations — thereby shifting an unlawful burden onto the county appraisal process and producing extreme, non-uniform overvaluation?

This is not a question of market opinion.

It is a question of constitutional authority.

Why Prior Acceptance Does Not Cure the Violation

The Texas Supreme Court has rejected the idea that constitutional violations can be cured by silence or prior payment.

In cases such as Harris County Appraisal District v. ETC Marketing, Ltd., the Court made clear that:

• Uniform-and-equal violations exist independently of market value disputes

• A taxpayer does not waive constitutional protection by paying a tax

• Courts may review appraisal methods, not just outcomes

In other words:

An unconstitutional system does not become constitutional through repetition.

Why This Is Bigger Than One Property

When appraisal systems shift burdens improperly or apply distorted valuation ratios — sometimes exceeding 200–300% of reasonable comparables — the harm is not isolated.

It undermines:

• Public confidence in taxation

• Constitutional limits on government power

• The principle that policy cannot override the Constitution

This is why constitutional review matters — not only for refunds or numbers, but for restoring lawful governance.

Closing Thought

The Texas Supreme Court has already spoken clearly:

Unconstitutional appraisal methods violate the law, regardless of prior acceptance.

The only remaining question is whether lower tribunals will honor that command.