Freedom Communications, Inc. v. Coronado, 372 S.W.3d 621

Freedom moved for summary judgment on defamation/privacy claims; trial court denied the motion.
Coronado and others were identified in a political advertisement placed during Zavaletta’s campaign.
Judge Abel Limas allegedly accepted $8,000 to rulings favorable to plaintiffs, including denying Freedom’s summary-judgment motion.
A federal plea agreement disclosed Limas’s improper interest and that his ruling was influenced by pecuniary gain, rendering the ruling void.
The court held appellate jurisdiction over the merits does not exist if the order is void, and vacated the court of appeals’ judgment to remand for proceedings in the trial court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the summary-judgment order is void for disqualification	Freedom argues the plea shows bad faith, warranting review.	Limas’s plea does not negate the merits; the ruling stands unless void.	Order void; no jurisdiction to address merits.
Whether appellate jurisdiction exists to review a void order	Freedom contends appellate review is permissible despite voidness.	Appellate courts lack authority over void judgments; must vacate and remand.	No jurisdiction to review merits; vacate and remand to trial court.

State ex rel. Latty v. Owens, 907 S.W.2d 484 (Tex. 1995) (jurisdictional issue when order may be void due to disqualification)
Univ. of Tex. Sw. Med. Ctr. of Dallas v. Margulis, 11 S.W.3d 186 (Tex. 2000) (review of void orders and appellate jurisdiction limitations)
Postal Mut. Indem. Co. v. Ellis, 169 S.W.2d 482 (Tex. 1943) (disqualification renders discretionary acts void; jurisdictional concern)
Tesco Am., Inc. v. Strong Indus., Inc., 221 S.W.3d 550 (Tex. 2006) (disqualified judge’s acts are void)
Elliott v. Scott, 25 S.W.2d 150 (Tex. 1930) (judge is disqualified when order affects him personally or pecuniarily)
Barth/related Tex. cases cited in opinion, 11 S.W.3d 186 (Tex. 2000) (related to appellate jurisdiction and void judgments)