Aracely Enterprises, LLC v. Sesatty Enterprises, LLC, 13-24-00058-CV

The dispute arose over the possession of a commercial plaza in McAllen, Texas, owned by Sesatty Enterprises, LLC (Sesatty).
In 2022, Aracely Gonzalez (not a party here) leased units in the plaza and later, Sesatty and Aracely Enterprises, LLC entered a Real Estate Sale Agreement for seller-financing of the entire plaza.
After executing the Sale Agreement, Aracely Enterprises took actions consistent with ownership: paid plaza expenses, made repairs, and collected rents from tenants.
Sesatty was unable to close with clean title; both parties blamed each other for non-performance under the contract.
When Aracely stopped making payments, Sesatty initiated a forcible detainer (eviction) action and victory was granted at both the justice court and county court levels.
Aracely challenged jurisdiction in the county court, alleging title issues intertwined with possession, and appealed when denied; at the same time, a related title dispute was active in district court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the justice and county courts had jurisdiction given title issues	Sesatty: Only possession at issue; court can decide	Aracely: Title dispute intertwined; court lacked jurisdiction	Court lacked jurisdiction: Title determination needed
Whether forfeiture of appellate jurisdiction applies under Tex. Prop. Code § 24.007	Sesatty: Statute bars appellate review	Aracely: Statute does not preclude review of jurisdiction	Statute does not preclude jurisdiction review
Whether a landlord-tenant relationship existed	Sesatty: Implied by payments made, eviction notices	Aracely: Only Sales Agreement exists—no lease, acts as owner	No landlord-tenant relationship shown
Effect of Aracely not depositing rent in court registry	Sesatty: Required by law, so judgment should stand	Aracely: Only relevant if court had jurisdiction	Court: No effect, as there was no jurisdiction anyway

Yarto v. Gilliland, 287 S.W.3d 83 (Tex. App.—Corpus Christi–Edinburg 2009) (lack of landlord-tenant relationship and presence of title dispute deprives justice and county courts of jurisdiction over forcible detainer)
Ward v. Malone, 115 S.W.3d 267 (Tex. App.—Corpus Christi–Edinburg 2003) (jurisdiction lacking in forcible detainer action if title is in dispute)
Salaymeh v. Plaza Centro, LLC, 264 S.W.3d 431 (Tex. App.—Houston [14th Dist.] 2008) (county court's jurisdiction in forcible detainer appeal is limited to that of the justice court)
Alanis v. Wells Fargo Bank Nat'l Ass'n, 616 S.W.3d 1 (Tex. App.—San Antonio 2020) (county court can't have jurisdiction if the justice court did not)
Rice v. Pinney, 51 S.W.3d 705 (Tex. App.—Dallas 2001) (review of jurisdiction not foreclosed by Tex. Prop. Code § 24.007)