Unreported / Non-Citable
Background
Nathan Ryan Wells filed a petition for writ of mandamus with the Texas Tenth Court of Appeals on November 3, 2026. The petition sought extraordinary relief against two separate district judges: one presiding in Limestone County and another presiding in San Jacinto County. The proceeding was designated as an original proceeding, meaning Wells invoked the appellate court’s original jurisdiction to issue writs rather than pursuing an appeal from a final judgment.
The petition presented a threshold jurisdictional question regarding the geographic scope of the Tenth Court of Appeals’ authority. Under the Texas Government Code, the state’s intermediate appellate courts are organized into distinct districts with defined territorial boundaries. The Tenth Court of Appeals exercises jurisdiction over specific counties, while San Jacinto County falls within the Ninth Court of Appeals District. This statutory allocation of judicial authority became the dispositive factor for one portion of Wells’s petition.
The Court’s Holding
The Tenth Court of Appeals issued a memorandum opinion authored by Chief Justice Johnson, joined by Justices Harris and Westerfeld, disposing of the petition through two distinct rulings. First, the court denied the petition for writ of mandamus to the extent it sought relief against the Limestone County district judge. This denial constituted a merits-based rejection of the request for extraordinary relief within the court’s proper territorial jurisdiction.
Second, the court dismissed the petition for want of jurisdiction to the extent it sought mandamus relief against the San Jacinto County district judge. The court explained that it lacks jurisdiction over proceedings in San Jacinto County because that county lies within the Ninth Court of Appeals District. Consequently, the Tenth Court also lacks jurisdiction over a San Jacinto County district judge. The court cited Texas Government Code sections 22.201(j)–(k) and 22.221(b) as the statutory basis for this jurisdictional limitation.
The opinion thus resulted in a split disposition: denial on the merits for the Limestone County claim and dismissal for lack of jurisdiction for the San Jacinto County claim. The court did not elaborate on the underlying merits of Wells’s allegations against either judge, focusing instead on the procedural and jurisdictional framework governing the petition.
Key Takeaways
- The Tenth Court of Appeals denied mandamus relief against a Limestone County district judge on the merits while dismissing claims against a San Jacinto County district judge for lack of jurisdiction.
- San Jacinto County falls within the Ninth Court of Appeals District, depriving the Tenth Court of authority over proceedings or judges from that county.
- The court relied on Texas Government Code sections 22.201(j)–(k) and 22.221(b) to define the geographic boundaries of its original jurisdiction.
- The petition was disposed of through a memorandum opinion in an original proceeding, with the court distinguishing between denial (merits) and dismissal (jurisdiction) for the two separate claims.
Why It Matters
This opinion reinforces the strict statutory boundaries governing Texas intermediate appellate courts’ original jurisdiction. Practitioners seeking mandamus relief must carefully verify the proper appellate district for the target county, as filing in the wrong district results in dismissal rather than transfer or merits consideration. The decision also illustrates the procedural distinction between denying relief on the merits and dismissing for want of jurisdiction, a distinction that affects preclusion and refiling options.
For attorneys practicing in central and east Texas, the case serves as a reminder that the Tenth Court’s authority does not extend to San Jacinto County, despite any geographic proximity or convenience. Proper venue in original proceedings requires consultation of the specific statutory assignments in the Texas Government Code to avoid jurisdictional dismissal.