Karen MC Andrews and John Lowe v. Jody Lowe and Phyniss Donald Lowe, 01-16-00836-CV

Appellants Karen McAndrews and John Lowe attempted to appeal multiple items arising from a suit affecting the parent–child relationship: a Rule 11 agreement, a June 3, 2015 order issuing a writ of attachment for McAndrews, and the trial court’s handling of a court reporter’s contest to McAndrews’s affidavit of inability to pay costs.
The clerk’s record shows the Rule 11 agreement was signed by parties and counsel and filed in the trial-court record but not signed by the judge and did not contain decretal language disposing of all claims and parties.
The writ-of-attachment order is a temporary/interlocutory order in a parent–child suit, and no statute authorizes an appeal of that interlocutory order.
The court reporter filed a contest to McAndrews’s affidavit of inability to pay; the docket sheet reflects a hearing and the notation “Request for free record—DENIED,” but no signed written order appears in the record.
Appellants did not file a timely appellate challenge to any purported order on the contest (they waited nearly a year before filing their notice of appeal).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the Rule 11 agreement is an appealable final judgment	The Rule 11 agreement disposes of all parties and issues and thus functions as a final judgment	Agreement is not a trial-court judgment because it was not signed by the judge and lacks decretal language	Not a final judgment; no appellate jurisdiction over the agreement
Whether the writ-of-attachment order is appealable	Appellants sought review of the June 3, 2015 writ of attachment	Respondents argued the order is interlocutory in a parent–child suit and not authorized for immediate appeal	Order is interlocutory and not appealable; no jurisdiction
Whether the docket-sheet entry denying free reporter’s record is an appealable order	Appellants treated the docket entry as a ruling denying free reporter’s record and appealed	Respondents argued the docket entry is not a signed written order and thus not appealable; also appellate relief was not timely sought	Docket-sheet entry is not a written order; even if it were, appellants failed to seek timely appellate review; no jurisdiction
Whether alleged refusal to comply with §52.047 or issues about reporter’s record affect jurisdiction	Appellants referenced refusal to comply and filed affidavits of inability to pay costs	Record contains no signed order contesting those affidavits; any reporter-record issues are moot if appeal dismissed	Issues are moot or unsupported by a signed, appealable order; appeal dismissed

Lehmann v. Har-Con Corp., 39 S.W.3d 191 (Tex. 2001) (final-judgment rule)
Ne. Indep. Sch. Dist. v. Aldridge, 400 S.W.2d 893 (Tex. 1966) (finality requires disposition of all parties and claims)
Stary v. DeBord, 967 S.W.2d 352 (Tex. 1998) (appellate jurisdiction only for final judgments or statutorily authorized interlocutory appeals)
Exito Elecs. Co. v. Trejo, 142 S.W.3d 302 (Tex. 2004) (filing a written agreement is a prerequisite to enforcement)
Schoendienst v. Haug, 399 S.W.3d 313 (Tex. App.—Austin 2013) (Rule 11 agreement alone is not a court order)
S & A Rest. Corp. v. Leal, 892 S.W.2d 855 (Tex. 1995) (judgment is rendered when court officially announces decision or files written memorandum)
In re Vaishangi, Inc., 442 S.W.3d 256 (Tex. 2014) (a Rule 11 agreement can be a judgment only if it meets final-judgment requirements)
In re Bill Heard Chevrolet, Ltd., 209 S.W.3d 311 (Tex. App.—Houston [1st Dist.] 2006) (docket-sheet entries generally are not part of the record for appeal and do not constitute orders)