Michael Reid v. UDR Texas Properties, LLC UDR Texas Properties, LLC, Successor to UDR Texas Properties, LP UDR the Cliffs, LLC UDR, Inc. And Western Residential, Inc., 02-15-00108-CV

Plaintiff Michael Reid sued multiple UDR entities in Tarrant County asserting claims including fraud, DTPA violations, wrongful handling of a lease-termination notice, and related contract/debt claims.
At trial only UDR The Cliffs LLC and UDR, Inc. appeared; the trial court’s Final Judgment expressly limited relief to the "Defendants named herein" and stated certain parties (UDR Texas Properties LLC; Western Residential, Inc./UDR Western Residential, Inc.) were not before the court and their claims were not considered.
During discovery and at trial there was confusion and conflicting sworn statements about which UDR entity employed the onsite staff who destroyed Reid’s notice; at trial counsel stipulated the management company was UDR Western Residential, Inc., and Reid sought to amend and join that entity as a defendant and to continue the trial.
The trial court denied Reid’s continuance and later entered Findings of Fact and Conclusions of Law indicating some claims and parties were not decided; Reid moved to set the excluded claims for trial and filed an appellate notice out of caution.
Reid moved the Court of Appeals under Tex. R. App. P. 2 to abate and stay the appeal pending clarification from the trial court about which parties were legally before the court and whether the appellate court has jurisdiction.
The Court of Appeals granted the motion and ordered all appellate proceedings and deadlines stayed until final clarification or further petition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Finality / Appellate jurisdiction	Judgment is not final because it expressly excluded some parties/issues; appeal may be premature.	(Implicit) Judgment labeled "Final" and purports to dispose of the case.	Court granted abatement and stay to resolve whether judgment is final as to all parties.
Intrinsically interlocutory / limiting language	The limiting language and findings show the judgment is intrinsically interlocutory and did not dispose of all parties/issues.	Judgment’s concluding language states it is final and appealable.	Court accepted need for clarification whether limiting language overcomes presumption of finality.
Service / general appearance / parties before the court	Some UDR entities never appeared or were not shown on docket; counsel should certify appearances so jurisdictional status is clear.	Defendants previously appeared in various filings and arguments (disputed scope).	Court ordered clarification from trial court/parties; stayed appeal pending resolution.
Judicial economy / potential multiplicity of suits	Abate avoids wasted costs and potentially duplicative litigation if judgment is not final as to all parties.	(Implicit) Proceeding on appeal now is appropriate since judgment purports to be final.	Court agreed abatement promotes judicial economy and preserved parties’ rights by staying the appeal.

Colquitt v. Brazoria County, 324 S.W.3d 539 (Tex. 2010) (appellate courts review only final judgments)
Cherokee Water Co. v. Ross, 698 S.W.2d 363 (Tex. 1985) (final judgment must dispose of all parties and issues)
New York Underwriters Ins. Co. v. Sanchez, 799 S.W.2d 677 (Tex. 1990) (appellate courts must determine jurisdiction sua sponte)
Lehmann v. Har-Con Corp., 39 S.W.3d 191 (Tex. 2001) (look to the four corners of the judgment and the record to determine finality)
Aldridge v. North East Indep. Sch. Dist., 400 S.W.2d 893 (Tex. 1966) (presumption of finality applies only as to parties legally before the court)
Trammell v. Rosen, 157 S.W. 1161 (Tex. 1913) (judgment that refuses to decide issues between parties not before the court affects finality)
Enserch Corp. v. Parker, 794 S.W.2d 2 (Tex. 1990) (corporate relationships and agency may bear on liability and joinder)