in Re Mark P. Hardwick, Individually and D/B/A Mark P. Hardwick Oil & Gas Properties and Mark P. Hardwick, LLC, 426 S.W.3d 151

Relators Challenged trial court’s denial of motion to transfer venue in a Harris County suit by Smith Energy against Hardwick and his LLC.
Smith Energy sued for breach of fiduciary duty, contract, fraud, and civil theft; prayed for forfeiture of mineral/royalty interests.
Relators argued mandatory venue under §65.023(a) ( Midland County) or §15.011 (county where property is located) due to requested forfeiture and real-property interests.
Amended petitions added an argument that venue was governed by a Harris County provision in the Muy Caliente agreement; amendments filed after the venue ruling.
Trial court denied transfer; the court acknowledged the standard for mandamus relief and the one-venue-rule under Rule 87; amendments after ruling were not to be considered for the challenged ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether §65.023(a) mandates venue in relators’ domicile.	Smith Energy argues forfeiture is not an injunctive writ.	Hardwick argues the suit seeks a writ of injunction via forfeiture.	No; forfeiture is not an injunction under §65.023(a).
Whether Smith Energy’s forfeiture claim falls under §15.011 real-property venue.	Smith Energy contends dominant purpose is contractual/fiduciary breach not real property.	Hardwick contends §15.011 applies because real-property interests are at stake.	Yes; the case is about recovering real property interests, so §15.011 applies.
Whether amended petitions after the venue ruling may alter the venue outcome.	Smith Energy asserts later amendments raise new venue grounds.	Relators argue amendments filed after ruling cannot be considered.	The later amendments could not be considered; the mandate rests on the March 19, 2012 ruling.
Standard of review for mandamus relief on mandatory venue.	N/A	N/A	Mandamus is appropriate to enforce mandatory venue; review is for abuse of discretion.
Whether Harris County venue based on the Muy Caliente clause controls.	Smith Energy relies on Harris County venue provision.	Relators note the clause was not pleaded for the initial ruling.	Not controlling here; the court focuses on §15.011; post-ruling pleadings not before the venue ruling.

In re Cont’l Airlines, Inc., 988 S.W.2d 733 (Tex. 1998) (mandamus review of mandatory venue decision; abuse-of-discretion standard)
In re Team Rocket, L.P., 256 S.W.3d 257 (Tex. 2008) (one-venue determination; Rule 87(5) limitations)
Applied Chemical Magnesias Corp., 206 S.W.3d 114 (Tex. 2006) (mandatory venue under 15.011 when real-property dispute present)
Yzaguirre v. KCS Resources, Inc., 53 S.W.3d 368 (Tex. 2001) (dominant-purpose test for venue under 15.011; real-property focus)
Bracewell v. Fair, 638 S.W.2d 612 (Tex. App.—Houston 1st Dist. 1982) (ultimate purpose determines section 15.011 applicability; not pleading style)