Baxter Oil Service, Ltd. v. Texas Commission on Environmental Quality
The trial court erred in granting the TCEQ’s plea to the jurisdiction. By the Order entered in connection with the Voda Site, the TCEQ attempts to impose monetary obligations on Baxter. Baxter is entitled to due process before it is deprived by the TCEQ of such property. Due process requires both adequate notice and an opportunity to be heard. The Order fails to comport with due process because it does not provide adequate notice. Specifically, the Order not only fails to inform Baxter of its appellate remedies, but affirmatively misrepresents the finality of the Order. The Order also fails to inform Baxter of the possible scope of its liability, thereby leaving Baxter with insufficient information with which to determine whether to fight the Order. Because the Order fails to comport with due process, it is void. And because the Order is void, it may be collaterally attacked. Accordingly, the TCEQ’s plea to the jurisdiction, which argued that Baxter could not collaterally attack the Order by means of a summary judgment motion, was without merit.