In re Mesa Petroleum Partners, LP, 538 S.W.3d 153

Mesa Petroleum sued Baytech, J. Cleo Thompson entities (JCT), and Delaware Basin Resources (DBR) alleging Mesa had a 15% interest in an AMI (Red Bull) and that defendants transferred Mesa’s interest, asserting contract, fraud, fiduciary-duty, conversion, trespass, and related claims.
After summary judgment disposed of most claims, a jury trial resulted in verdicts for Mesa on breach of the Participation Agreement and Joint Operating Agreement, gross negligence and willful misconduct, and awards (including attorney’s fees) totaling ~ $145 million.
Mesa filed a proposed final judgment and post-trial motions; the trial court held a five-hour hearing on February 27, 2017, and parties completed post-hearing briefing by March 28, 2017.
Nearly one year after the verdict and many months after briefing/hearing, the trial court had not entered final judgment; Mesa repeatedly requested entry and then sought mandamus to compel the judge to render judgment.
The trial court had a heavy multi-county docket and disposed of many matters during the relevant period; parties argued complexity of the record and post-verdict issues justified more time to rule.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court has ministerial duty to enter judgment on an unreconciled jury verdict	Mesa: Rules require entry of judgment after a jury trial; no irreconcilable findings exist so duty is ministerial	Real Parties: Some post-verdict issues (double recovery, joint-and-several liability, fees) require further judicial resolution before judgment	Court: Duty exists; no irreconcilable conflict in jury findings, so ministerial duty to enter judgment on verdict.
Whether Mesa sufficiently asked the court to render judgment	Mesa: Filed motion for judgment, attended and presented at five-hour hearing, sent multiple letters and proposed final judgments requesting entry	JCT: Record initially lacked transcription proving motion was presented; suggests Mesa did not properly present motion	Court: Mesa provided ample evidence (hearing transcript, letters, proposed judgments) showing it asked the court to render judgment.
Whether the trial court unreasonably delayed rendering judgment	Mesa: ~8–12 months since verdict/hearing/briefing with repeated requests constitutes unreasonable delay depriving appeal rights	Real Parties: Complexity, 4,000-page record, voluminous post-verdict briefing, and heavy docket justified additional time	Court: Considering totality (case complexity, prior hearing, briefing, docket), more than eight months was unreasonable; directed judgment within 30 days.

In re Reece, 341 S.W.3d 360 (Tex. 2011) (mandamus available to correct clear abuse or compel ministerial duty)
In re Prudential Ins. Co. of Am., 148 S.W.3d 124 (Tex. 2004) (standards for mandamus relief)
O'Connor v. First Court of Appeals, 837 S.W.2d 94 (Tex. 1992) (elements to obtain mandamus to compel ministerial act)
Traywick v. Goodrich, 364 S.W.2d 190 (Tex. 1963) (duty to enter judgment where jury findings are reconcilable)
Texas State Bd. of Exam’rs in Optometry v. Carp, 388 S.W.2d 409 (Tex. 1965) (mandamus compels trial court to proceed to judgment)
In re Ford Motor Co., 165 S.W.3d 315 (Tex. 2005) (relator bears burden to show entitlement to mandamus)
In re Salazar, 134 S.W.3d 357 (Tex.App.-Waco 2003) (reasonableness of delay judged by totality of circumstances)
Ho v. Univ. of Tex. at Arlington, 984 S.W.2d 672 (Tex.App.-Amarillo 1998) (trial court’s inherent authority to control docket)