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In re Islamic Society of Greater Houston — Mandamus Petition Denied for an Incomplete Record

Unreported / Non-Citable

Case
In re Islamic Society of Greater Houston, Inc.
Court
Texas First Court of Appeals
Judge
Justice Caughey; Justice Morgan; Justice Dokupil
Date Decided
October 30, 2026
Docket No.
01-26-01089-CV
Topics
Mandamus, Appellate Procedure, Plea to the Jurisdiction
Source
Read the full opinion

Background

Islamic Society of Greater Houston, Inc. sought a writ of mandamus challenging the trial court’s October 19, 2026 order denying its plea to the jurisdiction and motion to stay.

The underlying lawsuit was brought by Sonia Al-Zibdeh, Jamal Al-Zibdeh, Jawaher Al-Zibdeh Stratton, Summer Al-Zibdeh, and Yasmin Al-Zibdeh in the 133rd District Court of Harris County, with Judge Nicole Perdue presiding.

The Court’s Holding

The First Court of Appeals denied the mandamus petition because the Islamic Society failed to provide a complete record as required by Texas Rule of Appellate Procedure 52.7(a). The court explained that a party seeking extraordinary mandamus relief bears a critical obligation to supply the reviewing court with a complete and adequate record.

Because the deficient record prevented the Islamic Society from satisfying the procedural requirements for mandamus relief, the court did not decide whether the trial court clearly abused its discretion or whether an adequate alternative remedy existed. It also dismissed all pending motions as moot.

Key Takeaways

  • A mandamus relator must provide the appellate court with a complete and adequate record.
  • Failure to comply with Rule 52.7(a) can require denial of mandamus relief without consideration of the underlying jurisdictional challenge.
  • The court dismissed all pending motions as moot after denying the petition.

Why It Matters

The decision underscores that mandamus relief depends not only on showing a clear abuse of discretion and the absence of an adequate alternative remedy, but also on strict compliance with appellate procedural requirements. Even a potentially significant jurisdictional challenge may go unreviewed when the relator fails to furnish the record necessary to evaluate it.

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