Miguel Zaragoza Fuentes v. Evangelina Lopez Guzman Zaragoza, 01-16-00251-CV

Evangelina filed for divorce against Miguel in May 2014; several entities/individuals were named as co-respondents or otherwise implicated in property claims.
Evangelina nonsuited many of those intervenors at various times in 2015, but shortly before trial she filed a supplemental petition again naming several entities as co-respondents.
At a pretrial conference Evangelina said she would not seek affirmative relief from the intervenors and nonsuited them again on November 3, 2015.
The trial proceeded November 4–5, 2015; at the close of evidence the court orally announced it was "going to grant the divorce" and would accept Evangelina’s proposed property division, but stated this was subject to submission of attorney’s fees.
Several entities (including some not previously named) filed petitions to intervene on November 19 and December 10, 2015; the trial court signed the Final Decree of Divorce on December 21, 2015.
Evangelina moved to dismiss the intervenors’ appeals for lack of standing, arguing the interventions were untimely because the court had orally rendered judgment on November 5.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether intervenors timely intervened and thus have standing to appeal	Evangelina: oral pronouncement on Nov. 5 was final rendition of judgment, so interventions filed after that were untimely	Intervenors: petitions to intervene were filed before the court signed the written final decree on Dec. 21, so timely under Ledbetter	The oral pronouncement was conditional (subject to attorney’s fees) and not a final rendition; interventions filed before the written decree were timely, so intervenors have standing to appeal

Tex. Mut. Ins. Co. v. Ledbetter, 251 S.W.3d 31 (Tex. 2008) (petition in intervention is timely if filed before signing and rendition of final judgment)
State v. Naylor, 466 S.W.3d 783 (Tex. 2015) (oral pronouncement that disposes of all issues can constitute rendition of judgment)
Lehmann v. Har-Con Corp., 39 S.W.3d 191 (Tex. 2001) (finality requires disposition of all pending parties and claims)
Farm Bureau Cty. Mut. Ins. Co. v. Rogers, 455 S.W.3d 161 (Tex. 2015) (judgment not final if it fails to dispose of attorney’s fees claim)
McNally v. Guevara, 52 S.W.3d 195 (Tex. 2001) (attorney’s fees unresolved prevents final judgment)
Budinich v. Becton Dickinson & Co., 486 U.S. 196 (1988) (federal finality doctrine where merits decision with fees unresolved can still be final under federal law)