James Allen Martin and Victoria Martin v. Arthur P. Clarke, 09-16-00421-CV

Clarke, the landlord, obtained a Justice Court judgment awarding possession, $191 costs, and $1,400 in damages; Martins appealed to the county court for a trial de novo.
At the bench trial, Clarke (pro se) sought possession and back rent; he introduced a rent summary, lease, three‑day notice, communications, and inventory.
Clarke claimed a $5,075 arrearage based on his records; Martins testified they had paid $12,374 and had paid $1,450 into the court registry.
The trial court found Clarke entitled to possession and awarded $3,625 in damages (Clarke’s $5,075 claim minus the $1,450 paid into registry), plus interest.
Martins appealed pro se challenging sufficiency of the evidence; their brief lacked record cites and formal issue statements.
The Court of Appeals reviewed legal and factual sufficiency and affirmed the trial court’s judgment.

Issue	Plaintiff's Argument (Clarke)	Defendant's Argument (Martins)	Held
Whether Clarke was entitled to possession (forcible detainer)	Clarke argued he was landlord entitled to possession due to unpaid rent and presented lease, notice, payments record	Martins disputed amount owed, asserted payments totaling larger sums and paid into court registry	Affirmed: evidence supported Clarke’s superior right to immediate possession
Whether rent arrearage amount was supported	Clarke relied on rent payment summary and testimony showing unpaid amounts	Martins contended they paid more and produced testimony of payments and registry payment	Affirmed: court found $3,625 owed after credit for registry payment; evidence legally and factually sufficient
Whether Justice Court ruling properly re-litigated at trial de novo	Clarke relied on trial de novo procedure and presented evidence at county court	Martins sought reversal based on insufficiency and payment disputes	Rejected: de novo trial considered and county court’s factual findings stand
Whether appellate brief deficiencies precluded review	Clarke argued trial record supported judgment; appellee did not rely on appellant’s briefing defects	Martins filed a brief lacking citations and issues	Court construed pro se brief as challenging sufficiency and reviewed merits; affirmed

City of Keller v. Wilson, 168 S.W.3d 802 (Tex. 2005) (legal‑sufficiency standard and credibility deference)
Dow Chem. Co. v. Francis, 46 S.W.3d 237 (Tex. 2001) (factual‑sufficiency standard)
McClane v. New Caney Oaks Apartments, 416 S.W.3d 115 (Tex. App.—Beaumont 2013) (forcible detainer is summary remedy to decide possession)
Murphy v. Countrywide Home Loans, Inc., 199 S.W.3d 441 (Tex. App.—Houston [1st Dist.] 2006) (forcible detainer elements and rent claim guidance)
Rice v. Pinney, 51 S.W.3d 705 (Tex. App.—Dallas 2001) (plaintiff need not prove title, only superior right to immediate possession)