In Dallas County Appraisal Dist. v. Lal, 701 S.W.2d 44 (Tex. App.-Dallas 1985, writ ref'd n.r.e.), the plaintiff asserted a claim arising under article VIII, section 1 of the Texas Constitution for grossly excessive valuation of his property. See Lal, 701 S.W.2d at 45.
The taxpayer did not seek a purely legal determination regarding the constitutionality of a statute.
Instead, the taxpayer sought review of a highly factually bound issue, the value of property, which without question must first be reviewed by the appraisal review board.
Lal therefore involved an ordinary valuation dispute which is routinely handled through the administrative process.
Accordingly, in that case the Court held that the trial court lacked subject matter jurisdiction because the taxpayer failed to exhaust the statutory administrative procedures for contesting valuation. Id. at 46.