In RE PRAVEEN PANCHAKARLA v. the State of Texas, 602 S.W.3d 536

The TCPA requires trial courts to rule on a motion to dismiss "not later than the 30th day following the date the hearing on the motion concludes," and if no timely ruling is issued the motion is deemed denied by operation of law.
Hearing on the TCPA motion concluded Feb 18, 2019; the trial court granted the motion and dismissed claims on Feb 22, 2019.
Plaintiff filed a timely motion for reconsideration/new trial (filed Mar 22, 2019); the trial court vacated the Feb 22 dismissal and denied the TCPA motion on May 6, 2019, while still within its plenary power.
Defendants appealed and sought mandamus in the court of appeals, arguing the trial court lost authority after the 30-day TCPA deadline; the court of appeals conditionally granted mandamus and ordered reinstatement of the Feb 22 dismissal.
The Texas Supreme Court reviewed whether the TCPA prohibits a trial court from vacating a timely ruling after the 30-day window and held the TCPA does not strip the trial court of its plenary power to revisit interlocutory orders when no interlocutory appeal is pending.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the TCPA bars a trial court from vacating a timely ruling on a dismissal motion after the 30‑day statutory period	Trial court may vacate its prior ruling under its plenary power and reconsider the TCPA motion	Once the 30‑day deadline passes, the trial court lacks authority to act; a late ruling is void and the motion is denied by operation of law	The TCPA does not prohibit a trial court from vacating a timely ruling; the court retained plenary power absent a pending interlocutory appeal
Whether the court of appeals properly issued mandamus directing reinstatement of the dismissal order	Trial court acted within discretion; mandamus was not warranted	Court of appeals: trial court erred and order was void, mandamus appropriate	Court of appeals abused its discretion; conditional mandamus vacated and trial court action upheld

In re Lipsky, 460 S.W.3d 579 (Tex. 2015) (describing TCPA’s purpose and expedited dismissal framework)
Molinet v. Kimbrell, 356 S.W.3d 407 (Tex. 2011) (statutory interpretation reviewed de novo)
Fruehauf Corp. v. Carrillo, 848 S.W.2d 83 (Tex. 1993) (trial courts retain plenary power until judgments become final)
Lippincott v. Whisenhunt, 462 S.W.3d 507 (Tex. 2015) (courts should not add words to statutes)
TGS‑NOPEC Geophysical Co. v. Combs, 340 S.W.3d 432 (Tex. 2011) (rules on statutory construction)
In re Turner, 591 S.W.3d 121 (Tex. 2019) (mandamus standard of review)
In re Sw. Bell Tel. Co., 35 S.W.3d 602 (Tex. 2000) (orders issued beyond jurisdiction are void)