Wilder v. Campbell, 430 S.W.3d 474

Wilder, the district clerk of Tarrant County, appeals a temporary injunction barring cost collection from indigent parties absent Rule 145(d) findings.
Appellees filed uncontested affidavits of indigence in five divorce actions across five family district courts; final decrees stated costs would be borne by the incurring party, but contained no explicit Rule 145(d) findings that indigents received sufficient monetary awards.
Clerk issued bills of costs in 2012 relying on those decree language; threatened execution for costs.
Appellees sought injunctive relief in February 2013; the trial court granted a temporary injunction April 15, 2013 restraining the clerk from collecting costs from indigents.
The clerk appealed, raising jurisdiction, class-certification, and adequacy-of-remedy issues; the case was accelerated on appeal.
Rule 145 governs indigent status and costs, and Rule 145(d) requires explicit findings when costs may be charged despite indigence; no such findings were made in the underlying decrees.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court had jurisdiction to grant the injunction under §65.023(b).	Wilder argues court rendering the judgment handles injunctions.	Appellees contend the trial court may grant injunctions because relief can be independent of the judgment merits.	Jurisdiction lies with the rendering court; the injunction was improper.
Whether the case should be treated as a class action requiring certification.	Wilder argues no, as no class certification was pursued.	Appellees sought relief on behalf of themselves and others similarly situated.	Not reached/abdicated; the jurisdictional issue controls.
Whether there was an adequate legal remedy besides injunctive relief to correct costs taxed against indigents.	Wilder claims retax motions in individual courts are adequate.	Appellees contend multiple retax motions would create a multiplicity of suits and be inadequate.	No adequate remedy at law; however, the jurisdictional defect bars consideration.
Whether Rule 145(d) findings were required to support cost assessments against indigents.	Wilder asserts findings were unnecessary given boilerplate decree language.	Appellees argue rule 145(d) findings are required when indigents are taxed for costs.	Rule 145(d) requires explicit findings; none were present.

Carey v. Looney, 251 S.W.1040 (Tex. 1923) (injunctions may be issued by a court that did not render the judgment if relief can be granted independently of the judgment’s adjudicated matters)
Evans v. Pringle, 643 S.W.2d 116 (Tex. 1982) (mandatory provision; injunction to stay enforcement must be in court rendering the judgment when necessary to regulate processes under the judgment)
Hughes v. Morgan, 816 S.W.2d 557 (Tex.App.-Fort Worth 1991) (injunctions to affect judgment enforcement must be in court rendering the judgment; controlling precedent on jurisdiction)
Yates, 684 S.W.2d 669 (Tex. 1984) (uncontested affidavit of indigence conclusive; rule 145 aims to guarantee access to courts for indigents)
Kruegel v. Rawlins, 121 S.W. 216 (Dallas 1909) (injunctions attacking a judgment must be in the court that rendered it; historical jurisdictional principle)
Shor v. Pelican Oil & Gas Mgmt., LLC, 405 S.W.3d 737 (Tex.App.-Houston 2013) (injunctions may target nonparties where not attacking judgment validity; limits of section 65.023(b))
Repka v. American National Ins. Co., 143 Tex. 542 (Tex. 1945) (equity may address multiplicity of suits; adequacy of legal remedies evaluated in context)