Rowden v. Texas Catastrophe Property Insurance Ass'n
Ruby Rowden, d/b/a The Aloha Motel, filed suit against Texas Catastrophe Property Insurance Association (TCPIA) in Nueces County, Texas, after sustaining property loss during Hurricane Allen and rejecting TCPIA's settlement offer. TCPIA responded with a Plea to the Jurisdiction, arguing that the case should have been filed in Travis County and that Rowden had not exhausted her administrative remedies under the Texas Catastrophe Property Insurance Pool Act, TEX.INS.CODE ANN. art. 21.49. The trial court dismissed the suit without prejudice. Rowden appealed, contending the trial court had jurisdiction and venue in Nueces County, that the statute's language was permissive, and that her due process rights were violated. The appellate court affirmed the trial court's judgment, ruling that the statutory procedure for review in Travis County was mandatory and jurisdictional, and that Rowden had failed to exhaust administrative remedies and provide proper briefing for all points of error.