MacK B. Yates v. Harris County, City of Houston, Houston Independent School District, and Houston Community College System, 01-16-00086-CV

Appellees (Harris County, City of Houston, HISD, HCCS) sued multiple owners, including pro se appellant Mack B. Yates, for delinquent property taxes, penalties, interest, costs, and attorney’s fees.
Yates filed an answer; at trial he was incarcerated and did not appear.
The trial court heard evidence in his absence and rendered a post-answer default judgment against all defendants, including Yates.
Yates timely filed a motion for new trial and a notice of appeal; he was later found indigent for appeal.
The clerk’s record was filed on appeal, but the court reporter filed an information sheet stating no reporter’s record was taken of the trial.
The appellate court addressed jurisdiction challenges and then considered whether the absence of a reporter’s record required reversal of the judgment against Yates.

Issue	Plaintiff's Argument (Yates)	Defendant's Argument (Appellees)	Held
Whether appellate jurisdiction exists despite defects in notice of appeal	Yates argued his notice was adequate to invoke appellate jurisdiction	Appellees argued notice misidentified trial court and failed to name appellate court, so appeal should be dismissed	Court: Yates made a bona fide attempt to invoke jurisdiction; appeal not dismissed
Whether failure to have a reporter’s record of a post-answer default trial requires reversal	Yates argued no reporter’s record was taken, so record incomplete and judgment reversible	Appellees implicitly argued judgment should stand despite lack of reporter’s record	Court: Reversed judgment as to Yates and remanded for new trial because absence of reporter’s record in post-answer default trial is reversible error
Whether trial court erred by entering judgment without notifying or ordering Yates's presence	Yates contended he was not notified/ordered to appear and judgment therefore improper	Appellees did not prevail on jurisdictional/merits of this separate claim	Court: Did not reach this issue after sustaining first issue (no additional relief warranted)

Tex. Lottery Comm’n v. First State Bank of DeQueen, 325 S.W.3d 628 (Tex. 2010) (standard of review for appellate jurisdiction)
Tex. Dep’t of Parks & Wildlife v. Miranda, 133 S.W.3d 217 (Tex. 2004) (standard of review for jurisdictional questions)
Sharif v. Par Tech, Inc., 135 S.W.3d 869 (Tex. App.—Houston [1st Dist.] 2004) (post-answer default judgments require record; absence of reporter’s record is reversible error)
Stoner v. Thompson, 578 S.W.2d 679 (Tex. 1979) (evidence required for judgments following trial rather than on pleadings)
Chase Bank v. Harris Cty. Water Control & Improvement Dist., 36 S.W.3d 654 (Tex. App.—Houston [1st Dist.] 2000) (no reporter’s record of post-answer default judgment requires reversal and remand)