Malika Riley v. Dean M. Deanda, 706 S.W.3d 578

Dean M. Deanda filed a forcible detainer (eviction) action against Malika Riley and other appellants, asserting ownership of property in Baytown, Texas via a general warranty deed.
The appellants counterclaimed ownership by adverse possession, alleging their mother mistakenly occupied the subject property continuously for over 10 years, inheriting it after her death.
Initial judgment in justice court favored Deanda; on appeal to county court, Deanda produced a later deed and moved for summary judgment.
The appellants contested jurisdiction, arguing that the dispute over title due to adverse possession precluded jurisdiction in justice or county court, and also sought abatement in favor of a pending district court suit about title.
County court denied motions and granted summary judgment for Deanda, ordering eviction; appellants appealed that judgment.
The First Court of Appeals considered whether the lower courts had subject-matter jurisdiction to adjudicate possession given the intertwined title dispute.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jurisdiction—Title vs. Possession	Deanda: Superior right by deed; possession can be decided without resolving title.	Riley: Title claim (adverse possession) is inextricably linked to possession, requiring district court jurisdiction.	Jurisdiction lacking—the adverse possession claim intertwined with possession deprived county/justice courts of power.
Existence of Landlord–Tenant Relationship	Deanda: Appellants are tenants at will.	Riley: No tenant relationship existed.	No landlord–tenant relationship; possession could not be decided independently of title.
Merits—Right to Possession	Deanda: Later deed prevails; no genuine title issue.	Riley: Genuine factual dispute on title created by adverse possession claim.	Court did not reach this; jurisdictional defect was dispositive.
Summary Judgment Properly Entered?	Deanda: Evidence shows clear ownership.	Riley: Material fact disputes; court lacked power.	Court vacated judgment—never had jurisdiction to decide.

Black v. Wash. Mut. Bank, 318 S.W.3d 414 (Tex. App.—Houston [1st Dist.] 2010) (county and justice courts lack power to adjudicate title issues in forcible detainer actions)
Gentry v. Marburger, 596 S.W.2d 201 (Tex. App.—Houston [1st Dist.] 1980) (adverse possession claims that are not facially defective deprive lower courts of jurisdiction over possession)
Dyer v. Cotton, 333 S.W.3d 703 (Tex. App.—Houston [1st Dist.] 2010) (recites elements needed to properly plead adverse possession)