Glenn Alexander Clamon v. Jeffrey Delong and Dennis Holmes, 477 S.W.3d 823

Plaintiffs Jeffrey DeLong and Dennis Holmes obtained a $98,408.77 default judgment against Glenn Clamon in California for claims arising from sale of tax-resolution services.
Plaintiffs filed an authenticated copy of the California judgment in Tarrant County, Texas, under the Uniform Enforcement of Foreign Judgments Act (UEFJA), which created a Texas judgment upon filing.
Clamon did not file any postjudgment motions in Texas (e.g., motion to vacate or stay) challenging the domesticated judgment during the trial court’s plenary period.
Clamon filed a restricted appeal and, after filing his notice of appeal, submitted a formal bill of exception seeking to include California pleadings and other documents that were not before the Texas court when it rendered judgment.
The trial court refused to sign Clamon’s bill of exception, finding there was no trial or evidentiary hearing and that no evidence had been excluded; it noted the domesticated judgment was created by filing under the UEFJA.
The Court of Appeals considered only the papers that were on file when the Texas judgment was rendered and affirmed the trial court’s judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. Trial court’s refusal to sign bill of exception to include California pleadings	Clamon: trial court excluded California pleadings and should sign bill to include them	DeLong & Holmes: no trial or evidentiary ruling occurred; nothing was excluded; bill noncompliant with Rule 33.2	Affirmed — bill properly refused because UEFJA filing created a Texas judgment, no trial/evidence was excluded, and Rule 33.2 requirements were unmet
2. Lack of personal jurisdiction in California	Clamon: California court lacked personal jurisdiction over him	Plaintiffs: authenticated foreign judgment creates prima facie case; burden shifts to Clamon to show why full faith and credit should not apply	Affirmed — court did not consider extrinsic jurisdictional materials because Clamon never filed a timely postjudgment challenge in Texas; no error apparent on record
3. Improper service under California law	Clamon: was not served in accordance with California law	Plaintiffs: domesticated judgment is presumptively valid; plaintiff met prima facie burden by filing authenticated judgment	Affirmed — same reason: procedural route for contesting service was not pursued in trial court, so documents attached postnotice are outside restricted-appeal record

Alexander v. Lynda’s Boutique, 134 S.W.3d 845 (Tex. 2004) (elements of restricted appeal)
Midstate Envtl. Servs., LP v. Peterson, 435 S.W.3d 287 (Tex. App. — Waco 2014) (face of the record for restricted appeals)
Gen. Elec. Co. v. Falcon Ridge Apartments, 811 S.W.2d 942 (Tex. 1991) (extrinsic evidence not considered on restricted appeal)
Walnut Equip. Leasing Co. v. Wu, 920 S.W.2d 285 (Tex. 1996) (filing a foreign judgment under UEFJA functions as petition and creates Texas judgment)
Jonsson v. Rand Racing, L.L.C., 270 S.W.3d 320 (Tex. App. — Dallas 2008) (authenticated foreign judgment shifts burden to debtor)
Markham v. Diversified Land & Expl. Co., 973 S.W.2d 437 (Tex. App. — Austin 1998) (default foreign judgments carry presumption of validity)
Tex. R. App. P. 33.2 (referenced via cases interpreting formal bill of exception requirements)