Error Preservation in Texas Civil Cases, January 3, 2021

January 3, 2021

Dear All:

Happy New Year! 2020 went out with a bang, error preservation-wise. Not because of any Supreme Court rulings, but because of the number of rulings, and topics addressed, by the courts of appeals. As the Table of Contents reveals, the courts were busy, busy this week–perhaps because some justices were trying to finish up things before leaving office. One thing Covid-19 has not slowed the last few months–the number of error preservation decisions in Texas Civil Cases. This year’s count, from September 1 until the end of 2020 is at least 175–virtually identical to the same period in 2018 (174) and 2016 (177), and exceeding 2019 (112) and 2018 (158).

Table of Contents

In USAA v. Menchaca, a plurality of the Supreme Court said it could review conflicting jury answers on appeal, without regard to whether a party made a pre-juror dismissal objection to the same. The El Paso Court now holds–in a reasoned opinion in a denial of a mandamus, and over a dissent–that a motion to correct the verdict timely raises such an objection

Conflicting Jury Answers

Here is an example of the need to get the trial court to set forth on the record its understanding of your opponent’s complaint–and to make sure that, if the trial court does the same on your complaint, that the record shows the trial court understands the complaint you made:

Jury Argument

Your complaint on appeal must comport with the complaint you made in the trial court

Expert

Remember: you have to bring your complaint to the trial court’s attention. Just including a complaint in a pleading does not necessarily do so, nor does the fact that your opponent put the complaint in its pleading

Judge (Assignment)

You have to make your complaint in a timely fashion–which sometimes does not require raising the complaint at the first available opportunity

Attorney
Attorney’s Fees (Segregation)
Capacity
Constitutionality
Evidence
Legal Sufficiency (Jury Trial)
Work-Related Injury

You have to comply with the pertinent rules

Jury Charge

You have to obtain a ruling on your complaint, or object to the trial court’s refusal to rule

Discovery
Sanctions

The Blurbs

In USAA v. Menchaca, a plurality of the Supreme Court said it could review conflicting jury answers on appeal, without regard to whether a party made a pre-juror dismissal objection to the same. The El Paso Court now holds–in a reasoned opinion in a denial of a mandamus, and over a dissent–that a motion to correct the verdict timely raises such an objection:

Conflicting Jury Answers: “The question here, then, is whether Villegas’s post-verdict motion could serve to preserve error sufficient to allow this Court to perform a merits review of the trial court’s [*20] grant of a new trial based on purportedly conflicting answers in the jury verdict.

Rule 295 of the Texas Rules of Civil Procedure provides that if a jury’s answers to questions in a purported verdict are in conflict, the trial court must instruct the jury of the nature of the problem, give the jury additional instructions as necessary, and allow the jury to deliberate further. Tex. R. Civ. P. 295. In light of this rule, we have previously held that if a party wants to preserve error with regard to a defective jury verdict, “[t]he trial court must be made aware of the conflict before the jury is discharged because, once the jury is discharged, a conflict in the jury’s answers cannot be reformed.” Rhey v. Redic, 408 S.W.3d 440, 464-65 (Tex.App.—El Paso 2013, no pet.) (internal citations and quotation marks omitted). Here, it is undisputed that after the jury rendered its verdict, but before it was discharged, the Villegas plaintiffs did not bring the issue to the trial court’s attention.

However, in Rhey, we were not asked to address nor did we face the issue of whether a post-discharge motion for new trial could also serve to preserve error. Thus, while Rhey confirmed that a motion to correct the verdict is one way of preserving error in a conflicting jury verdict, it did not preclude or otherwise address the possibility [*21] that there are other ways to preserve such error. To date, the Supreme Court of Texas has not definitively answered that question—indeed, the last time the issue arose, the Court splintered into three plurality positions, none of which garnered a majority. See USAA Texas Lloyds Company v. Menchaca, 545 S.W.3d 479, 517-19 (Tex. 2018). Absent guidance from our highest court, we find this to be an open question.

We turn, then, to Rule 33.1, the general standard for preservation of error set by the Texas Rules of Appellate Procedure. See Tex. R. App. P. 33.1(a). To demonstrate preservation of a complaint for appellate review, Rule 33.1 requires the record to show:

(1) the complaint was made to the trial court by a timely request, objection, or motion that:

(A) stated the grounds for the ruling that the complaining party sought from the trial court with sufficient specificity to make the trial court aware of the complaint, unless the specific grounds were apparent from the context; and

(B) complied with the requirements of the Texas Rules of Evidence or the Texas Rules of Civil or Appellate Procedure; and

(2) the trial court:

(A) ruled on the request, objection, or motion, either expressly or implicitly; or

(B) refused to rule on the request, objection, or motion, and the complaining party objected [*22] to the refusal.

Tex. R. App. P. 33.1(a).

Rule 33.1 governs the preservation of error unless another rule applies. Although Rule 295 of the Texas Rules of Civil Procedure governs the procedure for correcting a verdict, the rule itself does not address the issue of error preservation. As such, we may rely on Rule 33.1 of the Texas Rules of Appellate Procedure to determine if error was preserved. We hold that, in addition to a motion to correct the verdict under Tex. R. Civ. P. 295, a motion for new trial can also preserve a defect in a jury charge under Tex. R. App. P. 33.1 because the post-trial motion brings the error to the trial court’s attention close enough in time to provide it an opportunity to correct the error by ordering a new trial before appellate proceedings begin. We agree with the four-justice plurality in Menchaca that “[g]enerally, a party should object to conflicting answers before the trial court dismisses the jury. The absence of such an objection, however, should not prohibit us [as an appellate court] from reaching the issue of irreconcilable conflicts in jury findings.” Menchaca, 545 S.W.3d at 526-28 (Green, J., plurality op.).

In the absence of a motion to correct the verdict or a post-verdict motion such as a motion for mistrial or new trial—which cites a purportedly conflicting verdict as a basis for seeking relief—Rhey would apply, and error would not be preserved. But given that [*23] Villegas filed post-verdict motions that identified the conflicting jury answers as a ground for relief, we conclude that this basis for granting a new trial was properly raised with the trial court and not waived.” In re Auto., No. 08-18-00149-CV, 2020 Tex. App. LEXIS 10387, at *19-23 (Tex. App.—El Paso Dec. 30, 2020)

Here is an example of the need to get the trial court to set forth on the record its understanding of your opponent’s complaint–and to make sure that, if the trial court does the same on your complaint, that the record shows the trial court understands the complaint you made:

Jury Argument: “Chambers County objected [to its opponent’s jury argument about the contract said about termination] that the contract “does not say that.” The trial court overruled the objection, admonishing the jury that “[i]t’s argument. You have the evidence before you.” Chambers County did not offer any further explanation of its objection, though it complains now on appeal that the rebuttal argument was improper because the trial court had “already found in a prior summary judgment order that Pelco had no such right” to terminate and Pelco did not “plead that it had a right to terminate the [c]ontract based on” the provisions that were the subject of the rebuttal argument. The Rules of Appellate Procedure require that, to preserve an allegation of error for appellate review, the record must show a timely objection stating the grounds for the requested ruling with enough specificity to make the trial court aware of the complaint, unless the specific grounds were apparent from the context. See [*46] Tex. R. App. P. 33.1(a)(1)(A). From the language used in the objection and the response of the trial court, it is apparent that the trial court did not perceive the objection to be directed at the alleged violation of a prior order or pleading rules. Rather, the record reflects that the trial court perceived the objection to be a disagreement with Pelco’s interpretation of the evidence. Nor can we say that the context of the objection makes the specific grounds now complained of clear. We therefore conclude that the error alleged was not preserved at trial pursuant to the Texas Rules of Appellate Procedure.” Chambers Cty. v. Pelco Constr. Co., No. 01-18-00832-CV, 2020 Tex. App. LEXIS 10454, at *45-46 (Tex. App.—Houston [1st Dist.] Dec. 31, 2020)

Your complaint on appeal must comport with the complaint you made in the trial court:

Expert: “To preserve error for appellate review, a complaining party must make a timely [*5] and specific objection. See Tex. R. App. P. 33.1(a)(1). In the instant case, the record does not reflect that B.A.L. objected to Dr. Lackey’s testimony or his report on the basis that he was not a disinterested expert. Rather, the only objection B.A.L. made in the trial court as to Dr. Lackey involved whether Dr. Lackey had been properly proven to be an expert witness such that he would be allowed to remain in the courtroom after “the Rule” had been invoked. See Tex. R. Evid. 614. Based on the foregoing, we cannot say that B.A.L.’s objection to Dr. Lackey in the trial court comports with the complaint raised on appeal.” In re B.A.L., No. 10-20-00064-CV, 2020 Tex. App. LEXIS 10405, at *4-5 (Tex. App.—Waco Dec. 30, 2020)

Remember: you have to bring your complaint to the trial court’s attention. Just including a complaint in a pleading does not necessarily do so, nor does the fact that your opponent put the complaint in its pleading:

Judge (Assignment): “Here, the Department included in its Original Petition an objection to the assignment of this matter to an associate judge. According to A.G.’s appellate brief, she relied on the Department’s objection and asserts this matter was required to be heard by the referring court. Because it was not, A.G. argues she is entitled to a new trial on the merits before the referring court. However, we find the record indicates this issue is not properly before us.

Judicial economy requires that a trial court have the opportunity to correct an error before an appeal proceeds. . . . Therefore, as a prerequisite to the presentment of a complaint for appellate review, the record must reflect that the complaint was made to the trial court by a timely request, objection, or motion. Tex. R. App. P. 33.1. Here, the record shows that neither party urged, [*11] mentioned, or otherwise brought to the attention of the trial court the objection contained in the pleadings at any time prior to or at the time of the final hearing. Further, A.G. did not file a motion for new trial raising the issue of the failure to refer the matter back to the referring court. As such, A.G. has failed to preserve this issue for our review. . . . In re B.W., 99 S.W.3d 757, 760 (Tex. App.—Houston [1st Dist.] 2003, no pet.) (citing Patir v. MFC Int’l. Corp., 60 S.W.3d 355, 357 (Tex. App.—Houston [1st Dist.] 2001, no pet.) (requiring objection or otherwise bringing to attention of the trial court an error that could have been cured if the trial court had been given the opportunity to do so). We thus resolve this issue against A.G.” E.G., No. 07-20-00189-CV, 2020 Tex. App. LEXIS 10478, at *11 (Tex. App.—Amarillo Dec. 31, 2020)

You have to make your complaint in a timely fashion–which sometimes does not require raising the complaint at the first available opportunity:

Attorney: “In issue seven, Brown argues that the trial court erred by denying her motion to disqualify Hagan as Moore’s attorney. Specifically, Brown asserts that Moore and Johnson are opposing parties because both sought to be McKinzie’s guardian, and it is therefore impermissible under the rules of ethics for Hagan to represent both Moore and Johnson. Brown does not cite any legal authorities supporting her argument that two persons who apply to be named permanent guardian constitute opposing parties. See Tex. R. App. P. 38.1(i) Furthermore, the record reflects that Brown did not move to disqualify Hagan until November 14, 2018, which was six months after the trial. See Tex. R. App. P. 33.1(a). For all these reasons, we overrule issue seven. Having overruled each of Brown’s issues, we affirm the trial court’s judgment appointing Moore as McKinzie’s permanent guardian.” In the Guardianship of William Vernon McKinzie, No. 09-19-00124-CV, 2020 Tex. App. LEXIS 10373, at *34 (Tex. App.—Beaumont Dec. 30, 2020)

Attorney’s Fees (Segregation): “ A-1 contends Supermart waived any complaint about segregation. Although it did not object to admission of A-1’s attorney’s fees evidence when it was introduced, during the charge conference Acacia and Supermart objected that A-1 had not segregated its fees as to the claims between them. This objection was timely and sufficiently specific to preserve Supermart’s objection.” Young Yoo v. A 1 Mktg., No. 05-19-00031-CV, 2020 Tex. App. LEXIS 10318, at *15 (Tex. App.—Dallas Dec. 29, 2020)

Capacity: “In issue one, Psalms argues that the evidence is legally insufficient to support the trial court’s finding that Psalms breached a contract with Hogan-Rogers because she was not a party to the contract, which was signed by her husband, who was not a [*10] named party in the lawsuit. Hogan-Rogers argues that because Psalms failed to raise this challenge before trial, it has waived this issue for appellate review.

“[A] challenge to a party’s privity of contract is a challenge to capacity, not standing, and requires compliance with [R]ule 93 of the Texas Rules of Civil Procedure.” John C. Flood of DC, Inc. v. SuperMedia, L.L.C., 408 S.W.3d 645, 651 (Tex. App.-Dallas 2013, pet. denied); see also Tex. R. Civ. P. 93(1) (providing that a pleading challenging a plaintiff’s legal capacity to sue shall be verified by affidavit). Based on our review of the record, Psalms did not challenge Hogan-Rogers’s capacity in its pleadings. Psalms first mentioned this argument in its proposed amended findings of fact and conclusions of law, which Psalms filed seven days after trial. We conclude that because Psalms failed to challenge Hogan-Rogers’s capacity to sue in a verified pleading prior to trial, Psalms has waived this issue for our review.” Psalms Funeral Home Llc v. Hogan-Rogers, No. 09-19-00269-CV, 2020 Tex. App. LEXIS 10370, at *9 (Tex. App.—Beaumont Dec. 30, 2020)

Constitutionality: “In the trial court, after the court granted the Defendants’ motions to dismiss, but before the court awarded attorneys’ fees and assessed sanctions, Gensetix filed a response to BCM’s application for attorneys’ fees and sanctions. In that response Gensetix argued [*35] that the TCPA’s mandatory fee provision was unconstitutional in violation of the open-courts provision of the Texas Constitution and the First and Fourteenth Amendments to the United States Constitution. n. 3 n. 3–The Decker Parties initially argue that Gensetix failed to preserve this issue for review in the trial court. Because Gensetix raised the constitutionality issue in the trial court and obtained an implicit ruling from the trial court when the court signed the fee orders, we hold that error was preserved. See Tex. R. App. P. 33.1.” Gensetix, Inc. v. Baylor Coll. of Med., No. 14-19-00488-CV, 2020 Tex. App. LEXIS 10431, at *34-35 (Tex. App.—Houston [14th Dist.] Dec. 31, 2020)

Evidence: “El-Rayes complains that Lee disclosed the video more than a year after the discovery period ended in the case, and therefore, the video should have been automatically excluded under rule 193.6(a). See Tex. R. Civ. P. 193.6(a). However, El-Rayes does not direct us to any [*9] trial objection that the video had not been timely disclosed. To preserve error on appeal, a party must present to the trial court a timely request, motion, or objection, state the specific grounds therefore, and obtain a ruling that appears in the record. See Tex. R. App. P. 33.1(a). When an appellant raises an objection to evidence for the first time in a motion for new trial, the appellant must show a legitimate reason for not raising the objection at trial. See Lagrone v. State, 942 S.W.2d 602, 618 (Tex. Crim. App. 1997) (“If a defendant fails to object until after an objectionable question has been asked and answered, and he can show no legitimate reason to justify the delay, his objection is untimely and error is waived.”); Jones v. State, 111 S.W.3d 600, 604 (Tex. App.—Dallas 2003, pet. ref’d) (“Unless the defendant can show a legitimate reason for not timely objecting, error is waived . . . “); see generally Dallas Ry. & Terminal Co. v. Little, 109 S.W.2d 289, 295 (Tex. Civ. App.—Dallas 1937, writ dism’d) (discussing that an appellant “should not be heard to complain for the first time in its motion for new trial” if the appellant failed to object during trial). El-Rayes’s motion for new trial shows no reason to justify the delay in raising his objection that the video was untimely disclosed. We conclude that El-Rayes’s objection is untimely and that he has waived error.” Mohamed Ahmed El-Rayes v. Jong Lee, No. 05-19-00881-CV, 2020 Tex. App. LEXIS 10395, at *8-9 (Tex. App.—Dallas Dec. 30, 2020)

Legal Sufficiency (Jury Trial): “A legal sufficiency issue is preserved by “one of the following: (a) a motion for instructed verdict; (2) a motion for judgment notwithstanding the verdict; (3) an objection to the submission of the issue to the jury; (4) a motion to disregard the jury’s answer to a vital fact issue; or (5) a motion for new trial.” T.O. Stanley Boot Co., Inc. v. Bank of El Paso, 847 S.W.2d 218, 220 (Tex. 1992). Riley did not raise the issue of judgment for the amount of excess rush housekeeping fees in a motion for instructed verdict, a motion for judgment notwithstanding the verdict, an objection to the jury charge, a motion to disregard the jury’s verdict or a motion for new trial. He did, however, raise the issue in a post-judgment motion to modify the judgment, in which he argued that he was entitled to judgment in the amount of $320 as a matter of law because the jury found the surcharge on rush housekeeping fees arbitrary, capricious, or discriminatory and his testimony about the amount of the fees was not controverted. This challenge was, in substance, a motion for directed verdict or for judgment notwithstanding the verdict. We conclude [*42] that Riley preserved this issue for appellate review.” Riley v. Caridas, No. 01-19-00114-CV, 2020 Tex. App. LEXIS 10277, at *41-42 (Tex. App.—Houston [1st Dist.] Dec. 29, 2020)

Work-Related Injury: “Fluor counters that Salas “failed to preserve error on his argument that his report of his work-related injury constituted protected activity under § 451.001(3) because he did not timely assert this argument in his Response to F[luor]’s Motion for Summary Judgment.” Fluor claims that “Salas first raised this argument orally at the hearing on summary judgment and in a ‘Post-Hearing Brief,’ filed shortly after the hearing.” Salas responds that (1) his “opposition to summary judgment directly argued that [he] engaged in protected [conduct] under § 451.001, including specifically citing and quoting § 451.001(3)”, (2) he “also provided direct factual support for a protected act under § 451.001(3)”, and (3) “even if Salas had not sufficiently pleaded a protected act under 451.001(3), by arguing the issue at summary judgment hearing without objection, Fluor agreed to try this issue by express or implied consent of the parties under TRCP Rule 67.”

We reject Fluor’s waiver argument. First, [*15] we note that Salas’s live pleading does not limit his retaliatory discharge claim to section 451.001(1). In his first amended petition, Salas pleaded that Fluor “may not” terminate him “because [he] received an injury on the job and pursued protected activity under Labor Code Section 451.001.”

Second, Salas did not limit his summary judgment response to section 451.001(1); he cited to and discussed section 451.001(3) and also provided evidence to support an argument that he engaged in protected conduct under section 451.001(3). Under a liberal reading of Salas’s response along with his summary judgment evidence, Salas presented the argument that his report of his on-the-job injury constituted protected activity under section 451.001(3). See Richmond v. L.D. Brinkman & Co. (Tex.) Inc., 36 S.W.3d 903, 905 n.2 (Tex. App.—Dallas 2001, pet. denied) (liberally construing response to summary motion to include preemption argument although nonmovants did not specifically state the argument).

Third, Fluor acknowledges in its appellate brief (as well as in its response to Salas’s post-summary judgment hearing brief) that Salas “raised this argument orally at the hearing on summary judgment.” Although we do not have a transcript of the oral summary judgment hearing, Fluor admits that the issue of whether Salas’s report of his on-the-job injury constitutes protected conduct under section 451.001(3) was argued at the hearing. Additionally, [*16] the trial court’s summary judgment order states that the court considered the summary judgment motion, the summary judgment response, arguments of counsel, and the pleadings on file in granting summary judgment in favor of Fluor.

We conclude that Salas did not “fail[] to preserve error on his argument that his report of his work-related injury constituted protected activity under § 451.001(3)”.” Salas v. Fluor Daniel Servs. Corp., No. 14-18-01103-CV, 2020 Tex. App. LEXIS 10262, at *14-16 (Tex. App.—Houston [14th Dist.] Dec. 29, 2020)

You have to comply with the pertinent rules:

Jury Charge: “The jury charge, however, did not include a question regarding whether Hinojosa and LaFredo became formally married through that ceremony. Instead, the charge asked whether the men were “informally married,” and, if yes, on what date they were married.:

SPECIAL INSTRUCTION FOR QUESTION NUMBER 1

Two people are considered informally married if:

a. they agree to be married, and

b. after the agreement, they lived together in Texas as spouses, and

c. there represented to others that they were married.

QUESTION NUMBER 1

Are GUSTOVA NOEL HINOJOSA and STEVE PAUL LAFREDO informally married? . . . .

To preserve error in the charge, the objecting party must present a complaint to the trial court that [*14] distinctly designates the error and grounds for the objection. Tex. R. App. P. 33.1(a)(1); Tex. R. Civ. P. 272, 274; Ford Motor Co. v. Ledesma, 242 S.W.3d 32, 43 (Tex. 2007). Any complaint pertaining to an instruction is waived unless specifically included in the objection. Bishop, 553 S.W.3d at 674 (citing Sears, Roebuck & Co. v. Abell, 157 S.W.3d 886, 891 (Tex. App.—El Paso 2005, pet. denied)); Tex. R. Civ. P. 274. Objections to the charge and requests for instructions must comport with the arguments made on appeal. Bishop, 553 S.W.3d at 674 (citing Cont’l Cas. Co. v. Baker, 355 S.W.3d 375, 383 (Tex. App.—Houston [1st Dist.] 2011, no pet.)). If the objection at trial is not the same as the complaint on appeal, the issue has not been preserved for review. Id. . . .At the informal charge conference during trial, Hinojosa’s counsel explained he was requesting a question and special instruction regarding formal ceremonial marriage. Specifically, counsel argued the charge should include (i) a special instruction regarding ceremonial marriage stating that two people are formally married [*22] if they agreed to be married, attended a ceremony that married them, and the ceremony was officiated by someone who had the authority to do so, followed by (ii) the question of “Are Gus and Steve married?” At the formal charge conference, however, counsel did not request that special instruction to go with his proposed question on formal, ceremonial marriage, nor did he request any instruction that set out the requirements to establish the existence of a formal, ceremonial marriage under sections 2.001(a), 2.008, 2.201, or 2.202 of the family code. Hinojosa proposed no instructions or definitions on what was required to be formally married in Texas or elsewhere on October 26, 2000 or at any other purportedly relevant time. Hinojosa also did not request granulated questions for the jury to answer whether each of those requirements were met. Instead, Hinojosa submitted a proposed question that asked the jury whether he and LaFredo became married on October 26, 2000 without defining the term “married” or instructing the jury as to what requirements Hinojosa and LaFredo had to meet to become married under Texas law. Without such instructions or definitions, Hinojosa failed to submit a substantially correct proposed charge [*23] to obtain the fact findings necessary to establish that a formal, ceremonial marriage existed between he and LaFredo under Texas law. See, e.g., Watson, 918 S.W.2d at 645 (requested question insufficient to preserve error if legal term included in question is undefined); see also Janelli v. Janelli, 220 S.W.2d 255, 256 (Tex. Civ. App.—Dallas 1949, no writ) (evidence raised question of fact as to existence of ceremonial marriage).

Given the defects in Hinojosa’s proposed question on the existence of a formal, ceremonial marriage, we cannot conclude Hinojosa requested the question in substantially correct wording or that the trial court abused its discretion in refusing to submit it in the charge. The trial court’s failure to submit Hinojosa’s proposed question is, therefore, not grounds for reversal. We overrule Hinojosa’s first issue.” Hinojosa v. Lafredo, No. 05-18-01543-CV, 2020 Tex. App. LEXIS 10475, at *13-14, 21-23 (Tex. App.—Dallas Dec. 31, 2020)

You have to obtain a ruling on your complaint, or object to the trial court’s refusal to rule:

Discovery: “Appellant’s second and third arguments assert the trial court erred in denying appellant’s motion to dismiss because appellees failed to answer appellant’s requests for admissions, resulting in deemed admissions that admitted appellees’ entire case. See Tex. R. Civ. P. 198.1, 198.2(c). Appellant filed the motion to dismiss on the first day of trial.

During the trial, the parties discussed appellees’ failure to answer requests for admission, but appellant did not mention the motion to dismiss. Appellant does not refer this Court to any place in the record where the trial court ruled on the motion to dismiss. Therefore, appellant [*8] has not preserved error for appellate review. See Tex. R. App. P. 33.1(a)(2).” Mays v. Hunn, No. 05-19-00923-CV, 2020 Tex. App. LEXIS 10245, at *7-8 (Tex. App.—Dallas Dec. 28, 2020)

Sanctions: “To preserve error for appellate review, [*6] “the record must show that: (1) the complaint was made to the trial court by a timely request, objection, or motion . . . and (2) the trial court (A) ruled on the request, objection, or motion, either expressly or implicitly; or (B) refused to rule on the request, objection, or motion, and the complaining party objected to the refusal.” Tex. R. App. P. 33.1(a). In this case, appellant did not obtain a ruling on the motion for sanctions, and he does not direct us to any place in the record, and we have not found in the record, where he objected to the trial court’s refusal to rule. We conclude appellant has not preserved any error concerning the trial court’s failure to rule on his motion for sanctions.” Mays v. Hunn, No. 05-19-00923-CV, 2020 Tex. App. LEXIS 10245, at *5-6 (Tex. App.—Dallas Dec. 28, 2020)

All for now.  Y’all have a great week, and stay safe and well.

Yours, Steve Hayes

shayes@stevehayeslaw.com; 817/371-8759; www.stevehayeslaw.com

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