Combs v. STP Nuclear Operating Co.

OPINION

JAN P. PATTERSON, Justice.

Appellants Susan Combs, 1 Comptroller of Public Accounts of the State of Texas, and Greg Abbott, Attorney General of the State of Texas, 2 appeal from the trial court’s grant of summary judgment in favor of appellee STP Nuclear Operating Company (“STP”). In three issues, the Comptroller argues that the trial court erred in granting summary judgment in favor of STP because the State may properly collect independently procured insurance tax from STP consistent with Due Process, Equal Protection, and the McCar-ran-Ferguson Act. Alternatively, the Comptroller…