Unreported / Non-Citable
Background
Hans Dane Christian Truelson, proceeding without counsel, petitioned for a writ of mandamus in an underlying case pending in the 280th District Court of Harris County. He alleged that the court’s official reporter had failed or refused to provide a transcript “from the trial” despite his demands.
Truelson asked the First Court of Appeals to order the official court reporter, or any substitute reporter, to produce the transcript. The underlying proceeding was Briana Camille Truelson v. Hans Dane Christian Truelson, Cause No. 2026-40010, before Judge Damiane Dianne Curvey.
The Court’s Holding
The court denied the mandamus petition. It explained that Texas Government Code Section 22.221(b) authorizes a court of appeals to issue mandamus against certain judges within its district, but Truelson sought relief against a court reporter.
Under Section 22.221(a), the court lacked authority to issue mandamus against a court reporter unless the reporter was interfering with the court’s appellate jurisdiction. Because Truelson did not establish a basis for that authority or otherwise show entitlement to mandamus relief, the court denied the petition and dismissed all pending motions as moot.
Key Takeaways
- A Texas court of appeals generally cannot issue mandamus directly against a court reporter.
- Mandamus authority over a court reporter may exist when the reporter is interfering with the appellate court’s jurisdiction.
- A relator seeking a trial transcript must establish both the appellate court’s authority to act and an entitlement to mandamus relief.
Why It Matters
The opinion underscores the jurisdictional limits on original mandamus proceedings in Texas appellate courts. A court reporter’s alleged failure to provide a transcript does not, by itself, permit an appellate court to compel the reporter to act; the relator must show interference with the court’s appellate jurisdiction.