Sam Houston and Meera Singh v. Ally Financial, Inc., 03-14-00342-CV

Ally Financial sued William G. Houston on a lease for a 2011 Cadillac, obtained default judgment against him, recovered possession, and that judgment is not appealed here.
Ally also sued Sam Houston and Meera Singh (relatives/occupants) seeking possession; Ally nonsuited those claims while appellants pursued affirmative claims and counterclaims pro se.
The district court granted final summary judgment that appellants take nothing on their affirmative claims; appellants appealed pro se.
On appeal, appellants argued the courts applied an incorrect standard to pro se pleadings (challenging the courts’ failure to apply Haines v. Kerner), alleged prejudice from procedural rules that chill indigent pro se litigants, and raised other claims they had not preserved below.
The Third Court of Appeals affirmed the district court, concluding appellants raised issues not preserved or not properly before the court and found no reversible error.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Application of Haines v. Kerner to pro se pleadings	Ally: courts must apply ordinary preservation and briefing rules; no special treatment beyond binding precedent requiring fair process	Appellants: Haines requires courts to liberally construe pro se pleadings and to excuse preservation defects; failure to apply Haines was prejudicial	Court: Applied standard appellate preservation and briefing rules to pro se litigants; found no reversible error and affirmed
Preservation of appellate error	Ally: many complaints were not preserved below and thus are forfeited	Appellants: failure to object below does not erase prejudicial error tied to denying access and pro se treatment	Court: Enforced preservation rules (Tex. R. App. P. 33.1) and declined to consider unpreserved complaints
Summary judgment rulings	Ally: district court properly granted summary judgment against appellants on their claims	Appellants: visiting judge initially denied Ally’s MSJ, later granted by presiding judge—this indicates impropriety	Court: Found no reversible error in district court’s summary judgment process or result
Denial/dismissal related to pauperis status and transcripts	Ally: procedural disposition proper; transcript request denied	Appellants: denial of pauperis or access to transcript was punitive and denied access to courts	Court: Dismissed denial of pauperis status as moot and denied motion to provide transcript at no cost; no relief warranted

Haines v. Kerner, 404 U.S. 519 (1972) (pro se pleadings held to less stringent standards and should be liberally construed)
Cruz v. Beto, 405 U.S. 319 (1972) (protections for pro se litigants in prison litigation context)
Puckett v. Cox, 456 F.2d 233 (6th Cir. 1972) (treatment of pro se filings in appellate/trial contexts)
Mansfield State Bank v. Cohn, 573 S.W.2d 181 (Tex. 1978) (Texas Supreme Court: apply same procedural/substantive standards to pro se litigants to avoid unfair advantage)