Teague - Supreme Court of Texas

addition, the Court fbmd that Teague had hiled to comply with this alleged stahtory
prerequis'i and as a result, an incurable jdsdictid defect existed which deprived the
court of jurisdiction. (CR at 185). The trial court Med to address Teague's c b that
the ordinance and statute were uncomtitutionsrl. Id.
From the trial court's ruling, Teague filed an appeal in addition to a petition fir
writ of injunction. Teague's request for a writ of injunction was granted by the court of
ap@s and the City was prohibited km acting on its order. In re Tea*, 22006 WL
302 123 (Tex. Amp.-Fort Worth Feb. 6,2006, orig. proceeding) (memo. ope).
Subsequently, the court of appeals reversed the trial court's decision hling that Teague
had complied with Ehe clear and unamb'ious language of Chapter 214 when he fled his
vded petition challenging the City's order as illegal and stating the grounds of the
illegality. Teague v. Ci@ of Jachhro, 190 S.W.3d 813,820 (Tex App.4ort Worth
2006, p& filed). Due to the fact that it sustained Teagus's first point of srrm under
Chapter 214, the court of appeals had no need to reach his decIamtory and injunctive
claims. Id.
On or about May 15,2006, the City filed its Petition 'r Revim with this Court.
ThereolRer, the State of Texas @~~ refmed to as the "State") filed an Arnictcs
Curine brief on the City's behalf. Subsequently, this Court requested Briefs on the Merits
from the parties. Teague hereby respectfully submits his Brief an the Merits.