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Crampton v. Harper Property Management — Appeal dismissed because there was no reviewable order

Unreported / Non-Citable

Case
Joshua G. Crampton v. Harper Property Management Inc., Rudy Montez, Jon Montez, Carly Montez
Court
Texas Fourth Court of Appeals
Judge
Irene Rios (elected 2016); Lori I. Valenzuela (Greg Abbott, 2021); Lori Massey Brissette (Greg Abbott, 2024)
Date Decided
September 9, 2026
Docket No.
04-26-00585-CV
Topics
Appellate Jurisdiction; Final Judgments; Interlocutory Appeals; Dismissal
Source
Read the full opinion

Background

Joshua G. Crampton appealed in litigation against Harper Property Management Inc., Rudy Montez, Jon Montez, and Carly Montez arising from Bexar County Court at Law No. 10.

The appellate record contained neither a final judgment nor an appealable interlocutory order. The Fourth Court of Appeals ordered Crampton to explain by August 20, 2026, why the appeal should not be dismissed for lack of jurisdiction, but he did not respond.

The Court’s Holding

The court held that it lacked appellate jurisdiction. Texas appellate courts generally may review final judgments, as well as interlocutory orders when a statute expressly authorizes an immediate appeal, but the record contained no order in either category.

Because Crampton did not respond to the show-cause order and failed to establish a basis for jurisdiction, the court dismissed the appeal under Texas Rule of Appellate Procedure 42.3(a) and (c).

Key Takeaways

  • An appellate record must contain a final judgment or a statutorily appealable interlocutory order.
  • An appellant facing a jurisdictional show-cause order must timely identify a valid basis for appellate review.
  • Failure to establish jurisdiction or comply with the court’s directive may result in dismissal under Texas Rule of Appellate Procedure 42.3.

Why It Matters

The decision underscores that filing a notice of appeal does not itself create appellate jurisdiction. Counsel should confirm that the challenged ruling is final or independently appealable before pursuing review.

It also illustrates the practical importance of responding to jurisdictional show-cause orders: silence leaves the asserted jurisdictional defect unanswered and can lead directly to dismissal.

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