See id. Scarbrough argues, however, that “[t]he case at bar demonstrates a legal and factual pattern where the merits are inextricably intertwined with certain jurisdictional facts.” Specifically, she argues that a jury trial was necessary to determine standing because the question of standing was inter tition are questions of law regarding the construction of the terms of the Resolution, not questions of fact regarding the details of the Resolution’s implementation. The facts material to a determination of Scarbrough’s standing as to her ripe claims are complete, are jurisdictional, and are largely uncontested. No additional discovery is necessary to determine Scarbrough’s standing to assert her ripe claims, hence to decide the plea to the jurisdiction. See Bland, 34 S.W.3d at 555 (<HOLDING>); Miranda, 133 S.W.3d at 227-28 (holding that
recognizing that we lack jurisdiction to consider issues not raised in the parties briefs holding that exhaustion of issues is jurisdictional holding that we consider issues not raised at administrative level waived holding that we generally may not consider issues not raised before the bia holding that we consider relevant evidence submitted by parties when necessary to resolve jurisdictional issues raised