the Honorable Mark Henry, County Judge of Galveston County v. the Honorable Lonnie Cox, Judge of the 56th District Court of Galveston County, 01-15-00583-CV

Interlocutory appeal challenges a temporary injunction restoring Bonnie Quiroga; Galveston County Judge Henry appealed the injunction and the denial of his plea to the jurisdiction.
Temporary injunction entered July 6, 2015 requiring reinstatement and salary payment; Henry filed notices of interlocutory appeals (a) from the injunction and (b) from the denial of his plea to the jurisdiction.
The injunction suspended during the appeal as a matter of law; Rule 29.1(b) governs suspension for interlocutory appeals in civil cases.
Appellee seeks contempt and enforcement of the injunction; Henry argues automatic suspension prevents contempt and enforcement actions during the appeal.
The court analyzes whether Rule 24.2(a)(3) or Rule 29.1(b) controls suspension and whether stays under section 51.014(b) apply due to the additional appeal.
The court concludes that the temporary injunction was automatically suspended and Henry is not in contempt; all trial court proceedings are stayed during the pendency of the appeals.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Effect of notice of interlocutory appeal on injunction	Henry's appeal suspends injunction automatically	Noncompliance could be contemptible	Automatic suspension; no contempt for following it
Contempt implications during interlocutory appeal	Henry should be held in contempt for noncompliance	Compliance not required due to suspension	Not in contempt; injunction stayed during appeal
Governing rule for suspension in interlocutory appeals	Rule 24.2(a)(3) governs contempt and enforcement	Rule 29.1(b) specifically controls interlocutory appeals	Rule 29.1(b) controls; suspension automatic for interlocutory appeal
Relation of Rule 24.2(a)(3) to interlocutory appeal	Security can allow non-superseded relief	Rule 24.2(a)(3) not applicable to interlocutory appeals	Inapplicable to interlocutory appeal of temporary injunction
Stay provisions under 51.014(b) and effect on proceedings	Stay applies only to some proceedings	Stay extends to all trial proceedings during appeal	All proceedings stayed; further actions barred during pendency

Elizondo v. Williams, 643 S.W.3d 765 (Tex. App. – San Antonio 1982) (permanent injunction as final judgment)
In re Long, 984 S.W.2d 623 (Tex. 1999) (interlocutory appeals suspend judgments; Rule 6.001(b)(4))
City of Dallas v. North by West Entertainment, Ltd., 24 S.W.3d 917 (Tex. App. – Dallas 2000) (interlocutory appeal controls suspension; Rule 29.1(b))
City of San Antonio v. Clark, 554 S.W.732 (Tex. Civ. App. – San Antonio 1977) (interlocutory appeal can suspend injunctions without supersedeas bond)
City of Dallas v. North by West Entertainment, Ltd., 24 S.W.3d 917 (Tex. App. – Dallas 2000) (Rule 29.1(b) governs suspension in interlocutory appeal)
State Board of Educator Certification, 452 S.W.3d 802 (Tex. 2014) (Rule 24.2(a)(3) discussed in final-judgment context)
City of Seagoville v. Lytle, 227 S.W.3d 401 (Tex. App. – Dallas 2007) (injunctions involving money damages; stay implications)
Texas A&M University System v. Koseoglu, 233 S.W.3d 835 (Tex. 2007) (stay provisions and related stays in interlocutory context)
In re Texas Education Agency, 441 S.W.3d 747 (Tex. App. – Austin 2014) (mandatory nature of stay under 51.014(b))