Needville Independent School District v. S. P. J. S. T. Rest Home

KEITH, Justice.

Plaintiffs below appeal from a take nothing judgment entered after a jury trial. Needville Independent School District brought suit for delinquent taxes and City of Needville intervened seeking delinquent ad valorem taxes owed to it. The defendant answered by claiming that it was exempt from ad valorem taxation as an institution of purely public charity within the meaning of Tex.Const. art. VIII, § 2, and Tex.Rev.Civ.Stat.Ann. art. 7150, § 7 (Supp. 1978).

The Court instructed the jury that an institution is a purely public charity if it met each of these tests:

“First, it makes…