In re State, 355 S.W.3d 611

State sought to condemn a 39.619-acre fee tract and a 0.23-acre drainage easement from the Laws family property in Travis County for SH 130.
Laws subdivided the property into eight tracts; the trial court severed the condemnation into eight separate proceedings.
Nine LLCs intervened claiming interests as successors in title, but the State continued to treat the acquisition as a single parcel.
Appraisals diverged: State valued the whole as one economic unit, while Lawses valued each tract separately.
Eight severance orders were entered over the State’s objections; no valuation evidence was presented in the severance hearings.
Court grants mandamus to vacate the severance, finding interrelated issues and wasteful duplication would prejudice the State and the public.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether severing into eight separate actions was an abuse of discretion	Laws argues interrelatedness makes unitary valuation proper	State contends severance avoids prejudice and duplication of evidence	Yes; severance abused discretion due to interrelated issues and wasteful duplication.
Whether mandamus is an adequate remedy given appeal options	Laws would be able to appeal, but remedy would be inadequate	State argues appeal suffices	Yes; appellate remedy inadequate because eight trials would waste resources.
Whether valuation evidence may be based on subdivision or must use single economic unit	Lawses seek subdivision-based valuation for eight parcels	State argues for single economic unit valuation or Windham framework	Both units may be considered; owners may offer competing economic-unit theories with jury resolution.

State v. Windham, 837 S.W.2d 73 (Tex. 1992) (valuation may consider independent economic units or broader unit per Windham)
State v. Meyer, 403 S.W.2d 366 (Tex. 1966) (part taken valued as separate economic unit when appropriate)
City of Harlingen v. Sharboneau, 48 S.W.3d 177 (Tex. 2001) (disallows subdivision development method due to speculation)
In re Masonite Corp., 997 S.W.2d 194 (Tex. 1999) (mandamus when severance causes waste of resources)
In re Olshan Foundation Repair, 328 S.W.3d 883 (Tex. 2010) (mandamus standards for abuse of discretion and adequacy of remedy)
F.F.P. Operating Partners v. Duenez, 237 S.W.3d 680 (Tex. 2007) (factors for severance and convenience)
Guaranty Federal Savings Bank v. Horseshoe Operator Co., 793 S.W.2d 652 (Tex. 1990) ( severance considerations and relation to unity of ownership)
Windham (State v. Windham), - (Tex. 1992) (provided Windham framework referenced above)