in Re Stephen Patrick Black, Relator, 07-22-00031-CV

Relator Stephen Patrick Black, a civilly committed pro se litigant, sued psychologist Charles P. Woodrick for libel; the trial court initially dismissed and this court reversed on appeal and remanded.
On remand Woodrick moved for summary judgment; a virtual hearing was held October 25, 2021, after which the trial court took the matter under advisement and announced it would rule later.
Black sent file-stamped letters to the clerk (Nov. 8 & 22, 2021) and filed a Motion to Set Hearing by Submission on Dec. 27, 2021, then repeatedly inquired by phone without resolution.
On January 21, 2022, Black filed a petition for writ of mandamus asking the trial judge to render a final judgment and provide notice so he could pursue post-judgment and appellate remedies.
Black argued the judge abused discretion by not ruling within three months as stated in Rule 7(a)(2) of the Texas Rules of Judicial Administration and that the lack of notice denied due process.
The court denied mandamus: less than three months had passed; the Rules of Judicial Administration are nonbinding aspirational standards; mandamus cannot compel a particular ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Trial court delay in ruling on summary judgment	Black: judge abused discretion by not ruling timely (within three months)	Court/defendant: less than three months elapsed; TRJA time standards are nonbinding goals	Denied — no abuse of discretion shown; three-month target not per se mandatory
Failure to notify of final judgment / denial of due process	Black: lack of rendition/notice prevents post-judgment and appellate remedies	Court/defendant: no final judgment was rendered; mandamus cannot force a particular substantive ruling	Denied — no entitlement to mandamus to compel notice absent a rendered judgment

In re N. Cypress Med. Ctr. Operating Co., 559 S.W.3d 128 (Tex. 2018) (mandamus requires abuse of discretion and no adequate appellate remedy)
In re H.E.B. Grocery Co., L.P., 492 S.W.3d 300 (Tex. 2016) (mandamus standard reaffirmed)
Walker v. Packer, 827 S.W.2d 833 (Tex. 1992) (relator bears burden to prove mandamus requirements)
Downer v. Aquamarine Operators, Inc., 701 S.W.2d 238 (Tex. 1985) (definition of abuse of discretion)
Stoner v. Massey, 586 S.W.2d 843 (Tex. 1979) (requirements to establish ministerial duty for mandamus)
Texas State Bd. of Examiners in Optometry v. Carp, 388 S.W.2d 409 (Tex. 1965) (mandamus to compel timely disposition)
Malone v. PLH Grp. Inc., 570 S.W.3d 292 (Tex. App.—Houston [1st Dist.] 2018) (definition of rendition)
Ex parte Bates, 65 S.W.3d 133 (Tex. App.—Amarillo 2001) (reasonableness of delay judged case-by-case)