Hector A. Espinoza and Elizabeth Sanchez v. Osiel Lopez, 468 S.W.3d 692

Espinoza and Sanchez appeal a county court judgment in favor of Lopez in a forcible detainer action concerning 18908 Jasperwood Street, Waller, Texas 77484.
They claimed the justice court lacked jurisdiction due to a title dispute; the county court denied dismissal and later granted summary judgment in Lopez's favor.
Espinoza and Sanchez assert an oral agreement to purchase the Property, with possession and payments starting in March 2010, creating a potential equitable title issue.
Lopez contends the dispute is a possession issue, not a title dispute, and that the purported oral contract is unenforceable absent partial performance.
During 2010–2013 Espinoza and Sanchez possessed the Property, paid monthly amounts around $620.19, and made some improvements; they paid property taxes as claimed.
The trial court awarded Lopez back rent totaling $2,480.76 and attorney’s fees of $20,579.22; Espinoza and Sanchez challenge both the possessory judgment and fee award.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the justice court (and thus the county court) had jurisdiction	Espinoza and Sanchez contend title issues barred possession relief.	Lopez argues possession issues moot title question and jurisdiction remains for forcible detainer.	Lacked jurisdiction; title issues intertwined with possession invalidated forcible detainer.
Whether Lopez was entitled to rent	Espinoza and Sanchez challenge the rent amount as disputed and tied to oral purchase terms.	Lopez maintains rent consistent with alleged occupancy and terms.	Rent award sustained as part of the final judgment on appeal (not moot).
Whether Lopez was entitled to attorney’s fees	Espinoza and Sanchez dispute the attorney’s fees and amount.	Lopez seeks fees as prevailing party under the forcible detainer framework.	Attorney’s fees awarded; issues regarding amount were resolved in the final judgment.

Salaymeh v. Plaza Centro, LLC, 264 S.W.3d 431 (Tex. App.—Houston [14th Dist.] 2008) (jurisdiction for forcible detainer; title issues may bar possession)
Black v. Wash. Mut. Bank, 318 S.W.3d 414 (Tex. App.—Houston [1st Dist.] 2010) (proper forum; appellate jurisdiction limited by justice court's scope)
Ward v. Malone, 115 S.W.3d 267 (Tex. App.—Corpus Christi 2003) (appeals in forcible detainer limited by justice court jurisdiction)
Pinnacle Premier Props., Inc. v. Breton, 447 S.W.3d 558 (Tex. App.—Houston [14th Dist.] 2014) (title issues intertwined with possession affect jurisdiction)
Mitchell v. Armstrong Capital Corp., 911 S.W.2d 169 (Tex. App.—Houston [1st Dist.] 1995) (title dispute may deprive justice court of jurisdiction)
Dormady v. Dinero Land & Cattle Co., 61 S.W.3d 555 (Tex. App.—San Antonio 2001) (proof of ownership necessary to show superior right to possession)
Haith v. Drake, 596 S.W.2d 194 (Tex. Civ. App.—Houston [1st Dist.] 1980) (landlord-tenant relationship not strictly required for jurisdiction)
Bynum v. Lewis, 393 S.W.3d 916 (Tex. App.—Tyler 2013) (title issue as determinant of possession requires jurisdiction analysis)