Hous. Indep. Sch. Dist. v. Tex. Workforce Comm'n

Edward Smith, Justice *636We withdraw our opinion and judgment dated April 25, 2019, and substitute the following opinion and judgment in their place.

The Houston Independent School District (Houston ISD) sued the Texas Workforce Commission to recover allegedly overpaid unemployment taxes. See Tex. Lab. Code §§ 213.071 -.074. Both parties moved for summary judgment. After a hearing on the controlling question of law and the undisputed facts, the district court rendered final judgment granting the Workforce Commission's motion, denying Houston ISD's motion, and ordering each party to bear its own…