Frank M. Seliger v. Ethiopian Evangelical Church, 03-14-00621-CV

Appellant Frank Seliger leased church property from July 1, 2012 to June 30, 2013; after lease expired he remained as a month-to-month (holdover) tenant.
Church (Ethiopian Evangelical Church) informed Seliger in September 2013 it planned a January 2014 project and asked him to move; served Notice of Intent Not to Renew on January 6, 2014.
Seliger was served a 3-day notice to vacate on February 17, 2014 (deadline Feb. 28, 2014); forcible detainer actions followed with multiple trials.
Lower courts (Travis County Court at Law No. 1) entered judgment for the Church; Seliger appealed to the Third Court of Appeals.
Seliger’s core contention was lack of proper notice and reliance on a lease provision requiring three months’ written notice if the property were sold or for certain changes; Church argued sale provision is inapplicable and proper notices were given.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Seliger, a holdover tenant after receiving a 3‑day notice to vacate, had a right to possession	Seliger: he did not receive proper notice and invokes a 3‑month notice clause (allegedly applicable when property sold or for building)	Church: lease expired; Seliger became a month‑to‑month/holdover tenant; Church served Notice of Intent Not to Renew and a 3‑day notice—tenant not entitled to remain	Court upheld judgment for the Church; Seliger had no legal right to continue possession; writ of possession to issue

Coinmach Corp. v. Aspenwood Apartment Corp., 417 S.W.3d 909 (Tex. 2013) (holdover-tenant principles and landlord’s rights after lease expiration)
Gym‑N‑I‑Playgrounds, Inc. v. Snider, 220 S.W.3d 905 (Tex. 2007) (continuing possession after lease expiration creates holdover tenancy)
ICM Mortgage v. Jacob, 902 S.W.2d 527 (Tex. App.—El Paso 1994) (tenancy at will terminable on fair notice)
In re Brunson, 498 B.R. 160 (Bankr. W.D. Tex. 2013) (definition and treatment of tenancy at will)