Further, Appellees contended Hesener failed to demonstrate that he exhausted all administrative remedies available to him, including seeking any applicable tax exemptions, before filing his suit and thus lacked standing to maintain his claims.
is “invalid.” As to the governmental-immunity issue, Hesener contends that he “seeks only prospective injunctive relief from a tax sale, and a declaration to set aside the lien from an invalid assessment,” which he argues means that he “is not required to obtain legislative consent” to sue Appellees.
Garcia, 593 S.W.3d at 209 (recognizing “a narrow exception to immunity when a plaintiff seeks reimbursement of an allegedly unlawful tax, fee, or penalty that was paid involuntarily and under duress”).
That is, even construing Hesener’s pleadings liberally in his favor, his suit arises from the imposition of an automatically placed tax lien for unpaid ad valorem taxes—the basis of which he does not challenge—not the illegal action of any state official.
Because Hesener has not met his burden to show any exceptions to or waiver of Appellees’ governmental immunity from his claims, we affirm the trial court’s order granting Appellees’ plea to the jurisdiction.