In re Williams, 378 S.W.3d 503

Cadle obtained a Michigan judgment against Williams on July 31, 2001 for $22,107.12.
Cadle domesticated the Michigan judgment in Texas by filing an authenticated copy in Harris County on May 23, 2006 under Chapter 35.
On November 28, 2011, Cadle obtained a writ of garnishment against JP Morgan Chase to collect the Michigan judgment.
Williams moved to vacate the judgment and dissolve the garnishment writ, asserting no notice of the Michigan suit and that Chapter 35 procedures were not followed, rendering the Texas judgment and order void.
The trial court denied Williams’s motions; Williams sought mandamus relief in this Court, which was denied.
The court discussed mandamus standards, procedural bars, and the effect of potential void judgments under Texas law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether 35.004(b) notice was properly mailed	Williams contends clerk failed to mail notice.	Cadle contends clerk mailings complied with the statute and any lack of proof is not dispositive.	No abuse; record incomplete; cannot conclude clerk failed to mail.
Whether the Michigan judgment is void for inadequate service and thus voidable in Texas	Williams asserts improper service invalidates the Michigan judgment.	Cadle argues such challenges are governed by Texas procedural timelines; post-plenary-power challenges require bill of review.	Challenge barred; Texas procedural limits apply; no mandamus relief.
Whether Williams is entitled to mandamus relief against the trial court's rulings	Williams seeks mandamus to vacate or dissolve based on voidness and improper service.	Cadle asserts no abuse of discretion and that remedies at law exist and are time-barred.	denied; no mandamus relief.

In re Prudential Ins. Co., 148 S.W.3d 124 (Tex. 2004) (mandamus relief requires abuse of discretion and no adequate remedy at law)
Johnson v. Fourth Court of Appeals, 700 S.W.2d 916 (Tex. 1985) (abuse of discretion standard in mandamus review of factual issues)
In re Cerberus Capital Mgmt., 164 S.W.3d 379 (Tex. 2005) (mandamus review and proper application of law to facts)
Dunn v. Street, 938 S.W.2d 33 (Tex. 1997) (void orders and lack of adequate appellate remedy principles)
Board of Disciplinary Appeals v. McFall, 888 S.W.2d 471 (Tex. 1994) (procedural context for mandamus and void orders)
Custom Corporates, Inc. v. Security Storage, Inc., 207 S.W.3d 835 (Tex.App.-Houston [14th Dist.] 2006) (mandamus and record sufficiency in incomplete records)
Allen v. Tennant, 678 S.W.2d 743 (Tex.App.-Houston [14th Dist.] 1984) (foreign judgment void where notice not properly provided)
Malone v. Emmert Indus. Corp., 858 S.W.2d 547 (Tex.App.-Houston [14th Dist.] 1993) (timely bill of review as remedy after plenary power)
Walnut Equipment Leasing Co., Inc. v. Wu, 920 S.W.2d 285 (Tex. 1996) (timeliness of challenging foreign judgments)