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Dubai. Heart Hospital IV, L.P. v. King – Case Brief Summary (Texas)

In Dubai. Heart Hospital IV, L.P. v. King, 116 S.W.3d 831 (Tex. App.--Austin 2003, pet denied), the Austin Court of Appeals considered whether the 14-day filing deadline applicable to judicial appeals from decisions of the Texas Workforce Commission was a jurisdictional requirement. Heart Hosp., 116 S.W.3d at 834.

It reasoned that because filing deadlines limit the classes of cases that a district court may consider, the filing deadline is not merely a statutory prerequisite but is a jurisdictional requirement:

"We must begin our analysis by first determining whether compliance with the statutory fourteen-day deadline is jurisdictional. Failure of a party to comply with statutory requirements is no longer an absolute bar to review of an agency determination. Some statutory prerequisites, however, remain jurisdictional. This Court has distinguished "statutory prerequisites" from those matters that are "traditionally and undoubtedly elements of subject-matter jurisdiction." A jurisdictional statutory requirement is one that "defines, enlarges, or restricts the class of causes the court may decide or the relief the court may award." A statutory requirement that does none of these may nevertheless affect a plaintiff's right to relief, but it is not jurisdictional. Applying these principles, this Court has held that failure to exhaust all administrative remedies, including the timely filing of a motion for rehearing, is jurisdictional "because the filing of the motion for rehearing defines and restricts the kind of case a district court may hear." Similarly, the statutory fourteen-day deadline also defines and restricts the kind of case that district courts may hear." Id. at 834-35.

In Heart Hospital, the Austin Court of Appeals held that the tolling provision in Texas Civil Practice and Remedies Code section 16.064 does not apply to special statutory proceedings such as judicial review of agency determinations. Heart Hosp., 116 S.W.3d at 836.

Furthermore, it held that because filing deadlines are jurisdictional, equitable tolling theories do not apply. Id.