Kerry Heckman, on Behalf of Themselves and All Other Persons Similarly Situated v. Williamson County, 369 S.W.3d 137

Petitioners Heckman, Maisenbacher, Peterson, Newberry, and Stempko sued Williamson County and several judges under 42 U.S.C. § 1983 seeking injunctive and declaratory relief for alleged pretrial rights (counsel, self-representation, open-court proceedings).
Plaintiffs claimed indigent misdemeanor defendants in Williamson County were denied court-appointed counsel and access to open-court proceedings.
Defendants moved to dismiss for lack of jurisdiction, arguing lack of standing, ripeness, and mootness, plus that the trial court lacked equity jurisdiction in pending criminal proceedings.
Some named plaintiffs were later appointed counsel and their criminal cases concluded, and a visiting judge allegedly denied counsel to Heckman, Maisenbacher, and Peterson.
The court of appeals dismissed the suit for lack of standing and mooted claims, vacating the trial court’s denial of the plea to the jurisdiction.
The Supreme Court held that the case is within its appellate civil-jurisdiction, reversed the dismissal, and remanded for further proceedings on class-certification standing and intervening-events mootness.

Issue	Plaintiff's Argument	Defendant's Argument	Held
May a named plaintiff have standing to pursue some class claims even if not all claims have standing?	Heckman/Maisenbacher argued standing must exist for all class claims before certification.	Defendants argued lack of standing on any claim defeats class standing.	A named plaintiff need not have standing on every class claim to pursue certification.
Are the named plaintiffs’ claims moot by subsequent events, and can a class action survive mooting of individual claims?	Claims may persist under an inherently transitory claims exception.	Subsequent counsel appointments and policy changes moot the class claims.	Inherently transitory exception applies; remand to determine if intervening events truly moot the class; relation-back may preserve certification opportunity.
Is this appeal within the Texas Supreme Court’s criminal-law jurisdiction, given civil-class issues arise from criminal proceedings?	Case involves civil rights claims arising from criminal proceedings; not a pure criminal-law matter.	Issues arise from criminal proceedings and procedures; may be criminal-law matter.	The case is a civil justiciability issue (standing/ripeness/mootness) and does not present a criminal-law matter, preserving the Court’s civil jurisdiction.

Bowden v. Phillips Petroleum Co., 247 S.W.3d 690 (Tex. 2008) (standing and subclass certification principles in complex actions cited by Texas Supreme Court)
M.D. Anderson Cancer Ctr. v. Novak, 52 S.W.3d 704 (Tex. 2001) (standing and jurisdictional analysis in Texas class actions)
Williams v. Lara, 52 S.W.3d 171 (Tex. 2001) (standing, ripeness, and open courts context in Texas)
Geraghty v. United States, 445 U.S. 388 (U.S. 1980) (relation-back and mootness in class actions (federal guidance))
Gerstein v. Pugh, 420 U.S. 103 (U.S. 1975) (short-lived claims and pretrial rights context in mootness analysis)
Davis v. Federal Election Comm'n, 554 U.S. 724 (U.S. 2008) (standing requires concrete injury; separate standing for forms of relief)