in Re: Castle Texas Production Limited Partnership, 12-17-00178-CV

Castle Texas Production operated gas wells; the Long Trusts sued for breach and conversion; Castle counterclaimed and prevailed on counterclaim.
The 2001 trial-court judgment awarded Castle prejudgment interest; the appellate court remanded for recalculation of prejudgment interest.
On remand the trial court reopened the record, Castle waived prejudgment interest, and a 2009 judgment awarded postjudgment interest (which this Court affirmed); the Long Trusts appealed to the Texas Supreme Court only on the proper accrual date for postjudgment interest.
The Texas Supreme Court held postjudgment interest accrued from the trial court’s final 2009 judgment when remand required new evidence, reversed this Court, and remanded for the trial court to render judgment in accordance with that opinion.
On remand from the Supreme Court the trial court issued a letter ordering the record reopened to determine postjudgment interest (including the accrual period); Castle sought mandamus, arguing the trial court exceeded the Supreme Court’s mandate.
The Tyler Court of Appeals denied mandamus, holding the trial court did not clearly abuse discretion in reopening the record because it must determine whether the record at remand was sufficient to render a correct judgment; any error is reviewable on appeal from the new final judgment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court exceeded the Texas Supreme Court’s mandate by reopening the record to determine postjudgment interest (including accrual period)	Castle: Mandate required only a ministerial revision—change accrual to March 25, 2009—so reopening was beyond the mandate	Long Trusts/Respondent: The Supreme Court’s opinion set the legal rule and remanded; trial court must decide if record suffices and may reopen to take necessary evidence to render a correct judgment	Court: Denied mandamus. Trial court acted within its discretion to determine whether the record at remand was sufficient; reopening decisions are reviewable on appeal from the new judgment

Long v. Castle Tex. Prod. Ltd. P’ship, 426 S.W.3d 73 (Tex. 2014) (Supreme Court set rule on accrual date for postjudgment interest when remand requires new evidence)
In re Prudential Ins. Co. of Am., 148 S.W.3d 124 (Tex. 2004) (standards for mandamus and adequacy of appellate remedy)
Walker v. Packer, 827 S.W.2d 833 (Tex. 1992) (mandamus standard for clear abuse of discretion)
Lee v. Downey, 842 S.W.2d 646 (Tex. 1992) (mandamus available when lower court fails to follow supreme court mandate)
Cessna Aircraft Co. v. Aircraft Network, LLC, 345 S.W.3d 139 (Tex. App.—Dallas 2011) (appellate mandate limits trial court on remand)
State Dep’t of Highways & Pub. Transp. v. City of Timpson, 795 S.W.2d 24 (Tex. App.—Tyler 1990) (precedent on accrual date used by this Court previously)
Russell v. Russell, 478 S.W.3d 36 (Tex. App.—Houston [14th Dist.] 2015) (trial court retains discretion to comply with limited remand)