Sanadco Inc., a Texas Corporation Mahmoud Ahmed Isba Broadway Grocery, Inc. And Shariz, Inc. v. Glenn Hegar, in His Individual and Official Capacity as Comptroller of Public Accounts Office of Comptroller of Public Accounts for the State of Texas And Ken Paxton, in His Official Capacity as Attorney General of the State of Texas
This Accelerated Appeal Reply Brief is submitted by Appellants Sanadco Inc. et al., challenging the trial court’s judgment in Cause No. D-1-GN-13-4352. Appellants argue that the underlying administrative judgments, which support the Comptroller’s collection activities, are void and unenforceable. They contend that the audit procedures (AP92 and AP122) were not properly adopted in accordance with the Administrative Procedure Act (APA) requirements, leading to ultra vires conduct by the Comptroller. Appellants assert that the trial court abused its discretion by denying a temporary injunction against the Comptroller's enforcement activities, as the administrative orders lacked a final judgment and were nullified upon the filing of petitions for judicial review. They also argue that Chapter 112’s prepayment provisions are unconstitutional and inapplicable to their claims challenging the validity of rules and statutes.