Jai Dining Services (Odessa), Inc. v. Glenn Hegar, Comptroller of Public Accounts of the State of Texas, and the Office of the Comptroller of Public Accounts of the State of Texas
Jai Dining Services (Odessa), Inc. appealed the trial court’s dismissal of its claims challenging an assessment of sexually oriented business (SOB) fees by the Comptroller of Public Accounts of The State of Texas. Jai argued it was not an SOB and that the Comptroller retroactively applied rules, seeking declaratory judgments under the Uniform Declaratory Judgments Act (UDJA) and the Administrative Procedures Act (APA), alongside an ultra vires claim and a temporary injunction. The appellate court affirmed the dismissal, concluding that sovereign immunity barred the UDJA and ultra vires claims due to the redundant remedies doctrine. It also found that the APA claim lacked a justiciable controversy, as Jai filed its claim after the rule was applied and did not pursue a Chapter 112 claim for permanent relief. The court further noted that Jai did not properly plead a Chapter 112 claim, which would have allowed consideration of an oath of inability to pay, distinguishing its situation from the precedent set in EBS II.