Hamlin Collegiate ISD Loses Tax Abatement Agreement Appeal

Texas Fifteenth Court of Appeals
Ruling: A “Chapter 313” tax abatement agreement between an ISD and a company became invalid due to the application not being amended to contain updated info about a merger involving the affected company.

• ENGIE IR Holdings LLC and Hamlin Collegiate ISD v. Acting Texas Comptroller Kelly Hancock, No. 15-24-00058-CV, combined ($) majority opinion (Sept. 18, 2025) & dissenting opinion (Sept. 22, 2025).

Background

In 2022, Hamlin Collegiate ISD (HCISD) was one of the numerous school districts rushing to complete so-called Texas Tax Code Chapter 313 (“Chapter 313“) property tax agreements with companies with an eye toward Chapter 313’s expiration date of Dec. 31, 2022.

$520 Million Plant

HCISD and ENGIE Solar entered into a proposed Chapter 313 agreement whereby the company would construct a $520 million solar electricity generation plant in the district in exchange for property tax incentives.

Merger

After the application was submitted to then-Comptroller Glenn Hegar, ENGIE Solar was completely absorbed — via a merger — into an affiliated company (ENGIE IR), effectively making ENGIE Solar a non-existent entity.