Adriene Sibley v. Seminole Pipeline Company, LLC, Enterprise Products Operating, LLC, First Call Field Services Corp., and TDW Services, Inc., 01-15-00775-CV

Background

Seminole Pipeline sued Sibley (and others) alleging predecessors granted easements and defendants were interfering with pipeline access; trial court entered a temporary restraining order preserving access.
Sibley repeatedly removed the case to federal court (twice), sought mandamus relief, and filed multiple recusal motions against Judge Warren and later Judge Denman; removals were remanded and appeals dismissed.
After remand, Sibley filed multiple affirmative claims (declaratory relief, civil conspiracy, trespass/interference, abuse of process, negligence, IIED, unjust enrichment) and served discovery on nonparty employees; defendants moved to quash, for sanctions, and to strike pleadings.
Judges Denman and Warren found several of Sibley’s recusal motions groundless or dilatory, imposed monetary sanctions for removals and abusive filings, and the trial court struck Sibley’s claims for bad-faith abuse of the judicial process and dismissed her claims for lack of standing; Seminole nonsuited its own claims and final judgment awarded Sibley nothing.
Sibley appealed, challenging judge disqualification, the validity of sanctions and final judgment, and the dismissal for lack of standing.

Issues and Key Cases Cited

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Judge Warren was disqualified	Warren acted as counsel and incurred pecuniary interest by directing clerk to mail hearing notices	Judicial administrative acts (directing notices) do not make judge counsel or give pecuniary interest	Warren was not disqualified; mailing/administrative acts are legitimate judicial functions
Validity of sanctions (basis/authority)	Sanctions void because Seminole lacked standing to seek contract relief	Sanctions were proper against Sibley for litigation misconduct and abuse of process regardless of Seminole’s contract standing	Sanctions valid—court may sanction any party appearing for misconduct under rules/inherent authority
Whether sanctions/orders void while recusal motions pending	Judges Denman and Warren sanctioned while recusal motions were pending; orders therefore void	Recusal motions had been denied or were tertiary; Rule/statute permits action where denied or for repeated filings	Not void: Underwood had denied first recusal; Denman permissibly acted under tertiary-recusal rule; Warren lawfully proceeded on April 24 for good cause
Standing to pursue affirmative claims / dismissal for lack of standing	Sibley contends she has property interest (relies on prior summary judgment and TRO)	Defendants: Sibley produced no competent evidence she owns the parcel subject to easements; Robinson judgment reversed; TRO is temporary	Sibley lacked standing; dismissal affirmed because record had no competent proof she owned the specific land with the easements

Key Cases Cited

McElwee v. McElwee, 911 S.W.2d 182 (Tex. App.—Houston [1st Dist.] 1995) (writ denied) (standards for preserving new recusal arguments on appeal)
F.S. New Prods. v. Strong Indus., 129 S.W.3d 594 (Tex. App.—Houston [1st Dist.] 2003) (en banc) (when a judge is disqualified as counsel or has pecuniary interest)
Valdez v. Valdez, 930 S.W.2d 725 (Tex. App.—Houston [1st Dist.] 1996) (no writ) (judicial direction to clerk to notify party is legitimate judicial function)
In re Humphreys, 880 S.W.2d 402 (Tex. 1994) (standards for appellate review of orders rendered while recusal pending)
Metzger v. Sebek, 892 S.W.2d 20 (Tex. App.—Houston [1st Dist.] 1994) (writ denied) (trial court sanctions and limits when recusal motions pending)
Tittizer v. Union Gas, 171 S.W.3d 857 (Tex. 2005) (a party cannot complain on appeal about actions it requested below)
Gonzalez v. Guilbot, 315 S.W.3d 533 (Tex. 2010) (statutory construction of tertiary-recusal rule)
Exxon Corp. v. Emerald Oil & Gas Co., 331 S.W.3d 419 (Tex. 2010) (right to sue for injury to real property belongs to owner)