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Texas 13th Court of Appeals, Personal Injury & Tort, Real Estate

Texas Cordia Construction v. Cantu — Private Government Contractor Cannot Invoke Interlocutory Appeal as “Governmental Unit”; Derivative Sovereign Immunity Fact Question Survives Plea to Jurisdiction

automatic / June 8, 2026

The Thirteenth Court of Appeals dismissed a private contractor’s interlocutory appeal of a denied plea to the jurisdiction because a private LLC is not a “governmental unit” under § 51.014(a)(8); treating the filing as a mandamus petition, the court denied relief because the contractor’s own contract gave it sole responsibility for means and methods of construction, raising a fact question that defeats derivative sovereign immunity — a doctrine the Texas Supreme Court has not yet adopted.

Texas 15th Court of Appeals, Civil Procedure, Oil & Gas, Probate, Real Estate

Parker v. Parrack — Court Cannot Declare Rights of Non-Party in Adverse Possession Dispute Over Family Ranch; Fiduciary-Duty Deed Challenge Fails on Sufficiency Review

automatic / June 8, 2026

The Fifteenth Court of Appeals affirmed the jury’s finding that a sister did not breach her fiduciary duty in accepting a deed to mineral executive rights from her brother, but vacated the adverse-possession declaration because the company asserting ownership was never joined as a party, rendering the declaration advisory and jurisdictionally void.

Texas 2nd Court of Appeals, Appellate Procedure, Civil Procedure, Oil & Gas, Real Estate

Atmos Energy v. DPC Parker Properties — Order Enforcing Rule 11 Settlement Does Not Function as a Temporary Injunction and Is Not Subject to Interlocutory Appeal

automatic / June 8, 2026

The Fort Worth Court of Appeals dismissed Atmos Energy’s interlocutory appeal of a trial court order enforcing a Rule 11 mediated settlement in an eminent-domain dispute, holding that the order did not function as a temporary injunction because it compelled performance based on the parties’ own agreement rather than any merits determination.

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