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Click here for the full text of this decision FACTS:The parcel of land at issue was originally part of a single, jointly owned, 24.36-acre tract. In 1984, the tract was partitioned into two smaller tracts. Tract No. 1, the 8.51-acre tract at issue in this case, was conveyed to Emma Crews, Valda Crews and Eva Fay Gross (collectively, the Crewses). Tract No. 2, comprising the remaining 15.85 acres, was conveyed to Andrew C. Brown. In March 1989, the city of Houston sued the Crewses for unpaid ad valorem taxes for the years 1960 to 1989 on what the city described as a six-acre portion of the 8.51-acre tract. Harris County joined the tax suit, but Aldine Independent School District, the other local taxing authority, did not. The tax-suit petition described the assessed property as follows: “Tract 12 being 6.0 acres out of T.S. Roberts Survey Abstract 659 situated in Harris County, Texas, as shown in file number J659372 of the deed and plat records of Harris County, Texas.” The file number corresponded to the Harris County clerk’s file number for the partition deed. The final judgment in the tax suit did not reference the partition deed but orders the city and county to recover against the Crewses for taxes and other fees levied on “TR 12 AB 659 T.S. Roberts situated in Harris County,” and further orders the constable to seize and sell the property to satisfy the judgment. Following the tax judgment, the constable attempted to sell the property at public auction. When there were no bidders, the city acquired the property through a constable’s deed in 1991. The constable’s deed referenced the tax suit and resulting judgment by cause number, and described the property being conveyed as follows: “[A]ll of the estate, right, title and interest which the said Emma Crews, Valda Crews, and Eva Fay Gross had on the 5th day of February, 1991, or at any time afterwards, in and to the following land and premises, as described in said order of sale, viz: TR 12 AB 659 T S Roberts situated in Harris County, Texas.” AIC Management purchased the land from the city at a subsequent public sale in 1997. The 1997 constable’s deed also referenced the tax suit and judgment and describes the property being conveyed to AIC as “all of the state [sic], right, title and interest” in “TR 12 AB 659 T S Roberts situated in Harris County” that the city had acquired under the 1991 constable’s deed. About three years after AIC acquired the land, the city decided to expand George Bush Intercontinental Airport and filed a condemnation suit on the entire 24.36-acre tract. In the multiparty condemnation proceedings that followed, both the Crewses and AIC claimed ownership of the 8.51-acre tract. The Crewses moved for summary judgment, contending they still held title under the 1984 partition deed, because the property descriptions in both subsequent constable’s deeds were too vague to allow the property to be located on the ground and were thus insufficient to convey title. Aldine intervened to collect delinquent taxes on the property out of the condemnation proceeds, claiming it still held a superior tax lien because it was not made a party to the city’s 1989 tax suit. AIC cross-claimed against Aldine, contending it had no liability for taxes that accrued before its acquisition of the property and that Aldine’s lien was extinguished when it failed to join the 1989 suit. The trial court granted the Crewses’ motion for summary judgment, voided the constable’s deeds for insufficient property descriptions, and declared the Crewses the property’s sole owners. The court also granted summary judgment in Aldine’s favor and dismissed AIC’s cross-claim, because AIC had no interest in the property. The 1st Court of Appeals affirmed, holding that the Crewses held superior title under the 1984 partition deed, because the constable’s deeds contained insufficient descriptions to allow location of the property with reasonable certainty and therefore failed to convey title. The Texas Supreme Court granted AIC’s petition for review to consider the sufficiency of the property descriptions contained in the constable’s deeds and the county court’s jurisdiction to decide the issue. HOLDING:Reversed and remanded. First, the court concluded that the trial court had subject-matter jurisdiction to resolve any title dispute between AIC and the Crewses arising out of the city’s eminent-domain proceeding. First, the court noted that the 1st Court held that a heightened standard applies when gauging the sufficiency of property descriptions contained in constables’ or sheriffs’ deeds made by virtue of execution sales. The court found, however, that the 1st Court’s distinction has not been the law in Texas for more than a century. Instead, the court found that the law merely requires that “[b]oth voluntary and involuntary conveyances of land require a property description that would allow an individual to locate the conveyed property with reasonable certainty.” AIC, the court stated, contended that the property descriptions at issue, which convey “all of the prior owner’s interest” in “TR 12 AB 659 T.S. Roberts situated in Harris County,” were sufficient as a matter of law to convey all of the Crewses’ interest in the entire 8.51-acre Tract No. 1. The court noted its previous holding that deeds in which a property is described as simply “my property” are sufficient when extrinsic evidence shows that the party owns only one tract of land answering the description. In this case, the court stated, the Crewses conveyed all of their interest in “TR 12,” but the record does not demonstrate how Tract No. 12 was configured at the time. If the trial court were to find that in 1989 HCAD designated the entire 24-acre tract as Tract No. 12, the court agreed with AIC that it would be entitled to all of the Crewses’ interest in the 8.51-acre No. 1. But if HCAD identified Tract No. 12 at the time of the 1989 tax judgment as something less, be it three acres, six acres or something else, then AIC would be entitled to the part of Tract No. 12 that overlapped with the 8.51-acre Tract No. 1, and the Crewses would retain whatever land remains. In addition, the court noted, the constable’s deeds broadly conveyed all of the Crewses’ interest in Tract No. 12. If HCAD records, the court stated, showed the 1989 version of Tract No. 12 clearly drawn on a map or described by metes and bounds, the less reliable references to acreage in the tax-suit petition would not render the description ambiguous or insufficient. OPINION:O’Neill, J., delivered the opinion of the court. CONCURRENCE:Willett, J., filed a concurring opinion. “[B]ecause the jurisdictional question can be decided without recourse to legislative history, we should decide the jurisdictional question without recourse to legislative history.”

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