Texas Case Summaries

Texas 2nd Court of Appeals

Texas 2nd Court of Appeals, Civil Procedure, Personal Injury & Tort

Allen v. Bell Textron — Plaintiff Who Tells Court He Has No Additional Facts and Won’t Replead Forfeits Chance to Expand Negligence Theories After Special Exceptions Sustained

automatic / June 8, 2026

The Fort Worth Court of Appeals affirmed a take-nothing judgment for Bell Textron after an injured contractor’s counsel stated at a special-exceptions hearing he had no additional facts and would not replead, holding the plaintiff forfeited his opportunity to amend, the narrow jury charge was proper, and any collateral-source evidence error was harmless because the jury found no proximate cause.

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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