in Re Houston Housing Authority, 14-16-00249-CV

HHA obtained a forcible-detainer judgment in justice court against Bobbie Figures for possession of a Houston property; Judge Parrott entered judgment on December 30, 2015.
On January 15, 2016, Sonfronia Thompson (acting for Figures) wrote the justice court requesting the judgment be set aside because the defendant was indigent, elderly, and unrepresented.
On January 20, 2016, Judge Parrott set aside the judgment, reinstated the case, and reset it for trial; Figures (now with counsel) filed a Motion to Set Aside Judgment and Cancel Writ of Possession.
HHA sued in County Court at Law No. 3 seeking mandamus relief, contending the justice of the peace lacked jurisdiction because his plenary power had expired and he failed to state reasons for granting a new trial.
The county court denied mandamus; HHA appealed and also filed a mandamus petition in this Court; the parties were consolidated. By the time of briefing, Figures had vacated the property.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Mootness of appeal	HHA sought review of justice court order setting aside judgment; claimed ongoing relief needed	County/Judge argued the tenant vacated so no live controversy	Case is moot; appeal and mandamus dismissed
Applicability of capable-of-repetition-yet-evading-review exception	HHA contended future similar actions could evade review (relying on Thompson’s letter)	County argued HHA showed no reasonable expectation of recurrence and no basis to invoke exception	Exception not satisfied—HHA did not show expectation of recurrence or that it could not obtain review
Applicability of collateral-consequences exception	HHA asserted collateral consequences but did not specify harms	County argued no concrete, continuing disadvantage exists once possession ended	Exception not satisfied—HHA failed to identify a concrete, persistent disadvantage
Jurisdictional defect (plenary power expired; failure to state reasons)	HHA asserted the justice court’s January 20 order was void for lack of jurisdiction and for not stating reasons	County defended the order below; procedural posture shifted because possession ended	Court declined to reach merits because mootness deprived jurisdiction

Marshall v. Hous. Auth. of San Antonio, 198 S.W.3d 782 (Tex. 2006) (forcible-detainer actions concern only right to possession; vacancy can render appeal moot)
In re Kellogg Brown & Root, Inc., 166 S.W.3d 732 (Tex. 2005) (mootness doctrine: controversy can cease at any stage, including on appeal)
NCAA v. Jones, 1 S.W.3d 83 (Tex. 1999) (courts lack jurisdiction to decide moot controversies)
In re H & R Block Fin. Advisors, Inc., 262 S.W.3d 896 (Tex. App.—Houston [14th Dist.] 2008) (orig. proceeding) (orig. proceedings and mootness jurisdiction principles)
State v. Lodge, 608 S.W.2d 910 (Tex. 1980) (exceptions to mootness doctrine overview)
Blum v. Lanier, 997 S.W.2d 259 (Tex. 1999) (definition and requirements of capable-of-repetition-yet-evading-review)
Gen. Land Office v. OXY U.S.A., Inc., 789 S.W.2d 569 (Tex. 1990) (governmental parties may be limited in invoking mootness exceptions)
In re Uresti, 377 S.W.3d 696 (Tex. 2012) (requirements to invoke exceptions to mootness)
Reule v. RLZ Invs., 411 S.W.3d 31 (Tex. App.—Houston [14th Dist.] 2013) (collateral-consequences exception requires showing of concrete, persistent disadvantage)