Thomas W. Strong-Gribble v. Latif and Company LLC, 14-19-00576-CV

Strong‑Gribble owned residential property secured by an equity security instrument (deed of trust) containing a tenant‑at‑sufferance clause requiring surrender after foreclosure.
The deed of trust was foreclosed and Latif and Company LLC purchased the property at the foreclosure sale and served notice to vacate on occupants.
Strong‑Gribble refused to vacate; Latif filed a forcible detainer action in justice court, won, and Strong‑Gribble appealed pro se to the county court at law for a de novo bench trial.
At trial Strong‑Gribble argued Latif failed to prove a landlord‑tenant relationship, asserting Latif did not introduce the deed of trust as an exhibit and asked the court to abate because of a pending wrongful‑foreclosure suit.
The deed of trust had been attached to Strong‑Gribble’s answer and was in the county court’s record; the court was directed to that filing at trial and, presuming judicial notice of its file, relied on the deed and the foreclosure facts to find Latif had superior right to immediate possession.
The county court awarded possession to Latif; on appeal the Fourteenth Court of Appeals affirmed, holding there was sufficient proof of a landlord‑tenant relationship and superior right to possession.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Proof of landlord‑tenant relationship / superior right to immediate possession in post‑foreclosure forcible detainer	Strong‑Gribble: Latif failed to prove landlord‑tenant relationship because Latif did not admit the deed of trust at trial	Latif: Foreclosure purchaser + deed of trust with tenant‑at‑sufferance clause + notice to vacate establishes superior right to possession	Held: Court affirmed — deed in the record plus foreclosure facts established tenant‑at‑sufferance and superior right to possession
Admissibility / evidentiary effect of deed of trust that was filed but not formally admitted at bench trial	Strong‑Gribble: The deed was not admitted, so it is not evidence	Latif: The deed was in the court’s record and counsel pointed the court to it; trial court may take judicial notice of its records	Held: Court presumed the trial court took judicial notice of its file; the deed in the record was properly considered by the bench court

Espinoza v. Lopez, 468 S.W.3d 692 (Tex. App.—Houston [14th Dist.] 2015) (forcible detainer determines immediate possession)
Marshall v. Housing Authority of San Antonio, 198 S.W.3d 782 (Tex. 2006) (forcible detainer is speedy, simple remedy for possession)
Salaymeh v. Plaza Centro, LLC, 264 S.W.3d 431 (Tex. App.—Houston [14th Dist.] 2008) (plaintiff need only show sufficient evidence of ownership to demonstrate superior right to immediate possession)
Pinnacle Premier Props., Inc. v. Breton, 447 S.W.3d 558 (Tex. App.—Houston [14th Dist.] 2014) (tenant‑at‑sufferance clause plus foreclosure purchaser and notice supports forcible detainer recovery)
Goodman‑Delaney v. Grantham, 484 S.W.3d 171 (Tex. App.—Houston [14th Dist.] 2015) (forcible detainer requires proof of landlord‑tenant relationship)
In re K.F., 402 S.W.3d 497 (Tex. App.—Houston [14th Dist.] 2013) (bench court presumed to take judicial notice of its own file)