Rhonda Patrice Goodman-Delaney v. Marilynn Grantham
484 S.W.3d 171
| Tex. App. | 2015Background
- Mary Delaney owned a Houston home; she died intestate. Her husband James continued to live there, later married Rhonda Goodman-Delaney, and James died in 2014.
- Marilynn Grantham is one of Mary’s heirs; she sent a notice to vacate to Goodman-Delaney and filed a forcible detainer (eviction) in justice court.
- Justice court initially ruled for Goodman-Delaney; Grantham appealed to the county court at law for a trial de novo.
- At the county-court trial Grantham conceded there was no landlord–tenant relationship and that Goodman-Delaney paid no rent; the court nonetheless awarded Grantham rent and attorney’s fees and found Goodman-Delaney wrongfully possessed the property after James’s death.
- The court of appeals held that because no landlord–tenant relationship existed, the justice and county courts lacked jurisdiction over title disputes inherent in the case, vacated the county-court judgment as void, and dismissed the forcible detainer action for want of jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a forcible detainer action was properly before the justice/county court when no landlord–tenant relationship existed | Grantham sought possession and monetary relief (rent, fees) asserting superior right to possession as heir/owner | Goodman-Delaney argued there was no landlord–tenant relationship and no rent was due; possession followed from prior lawful occupancy with her husband | Court: Where no landlord–tenant relationship exists, forcible detainer would require resolving title; justice and county courts lack jurisdiction to decide title; case dismissed for want of jurisdiction |
| Whether the county-court judgment awarding rent and fees is valid despite lack of subject-matter jurisdiction | Grantham implicitly argued relief was proper on appeal | Goodman-Delaney argued judgment lacked legal basis because no tenancy existed | Court: Judgment is void for lack of jurisdiction and is vacated |
Key Cases Cited
- Geldard v. Watson, 214 S.W.3d 202 (Tex. App.—Texarkana 2007) (justice court lacks jurisdiction to adjudicate title when forcible detainer requires title determination)
- Dent v. Pines, 394 S.W.2d 266 (Tex. Civ. App.—Houston 1965) (forcible detainer requires evidence of landlord–tenant relationship; absence makes eviction judgment void)
- Aguilar v. Weber, 72 S.W.3d 729 (Tex. App.—Waco 2002) (contract disputes that resolve ownership cannot be litigated in justice court forcible detainer proceedings)
- Doggett v. Nitschke, 498 S.W.2d 339 (Tex. 1973) (county courts do not have jurisdiction to try questions of title to land)
- Rusk State Hosp. v. Black, 392 S.W.3d 88 (Tex. 2012) (subject-matter jurisdiction cannot be waived and may be raised sua sponte)
- Yarbrough v. Household Fin. Corp. III, 455 S.W.3d 277 (Tex. App.—Houston [14th Dist.] 2015) (reaffirms that forcible detainer depends on proof of landlord–tenant relationship)