dissenting.
The majority concludes that the appraisal district and the appraisal review board need not file an appeal bond pursuant to section 42.28 of the Texas Property Tax Code. Because the majority ignores a settled principle of law in the area of statutory construction, I respectfully dissent.
The statute in question could not be clearer. In the context of appealing a district court’s judgment on property tax matters, the legislature plainly states that there are only four (4) instances when an appeal bond is not required. In weaving an intricate web of legal implications and presumptions to support its conclusion, the majority blinks away a settled principle of statutory construction — Expressio unius est exclusio alterius. In other words, when a statute enumerates one or more persons or entities, it is considered to exclude persons or entities not specifically enumerated. As stated by this court:
The rule expressio unius est exclusio alterius is a sound one, frequently applied in the construction of statutes, and is applicable [to this case]. The inclusion of the specific limitation excludes all others.
Harris County v. Crooker, 112 Tex. 450, 458, 248 S.W. 652, 655 (1923); see also State v. Mauritz-Wells Co., 141 Tex. 634, 639, 175 S.W.2d 238, 241 (1943).
Inasmuch as the statute in question specifically lists the four (4) instances when an appeal bond is not required, I would likewise hold, as did the court of appeals, that the statute expressly excludes the appraisal review board and the appraisal district. For this reason, I dissent from thé majority’s disposition of this case.