Wilma Reynolds and Carl W. Gordon v. Quantlab Trading Partners US, LLP, Quantlab Incentive Partners I, LLC, Quantlab Financial, LLC, and David Reynolds
14-23-00829-CV
Tex. App.Oct 31, 2024Background
- Extensive litigation between Wilma Reynolds and David Reynolds originated from their 2008 divorce in Brazoria County, Texas.
- A final divorce judgment was entered on May 18, 2009, disposing of all community property claims.
- Wilma, aided by her attorney Carl Gordon, subsequently filed numerous appellate and post-judgment proceedings over several years, attempting to relitigate property division.
- In 2023, Wilma filed a new petition in the same cause number, asserting claims against David and Quantlab regarding alleged misrepresentations of asset value and resulting fraud in the divorce division.
- The trial court dismissed her claims and sanctioned Wilma and Gordon with an order to pay more than $95,000 in attorneys’ fees and costs.
- The appeals court considered whether the trial court had jurisdiction to issue the dismissal and sanctions orders.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Dismissal under Rule 165A | Improper to dismiss under Rule 165A | Petition legally ineffective; case closed | Dismissal void; trial court lacked jurisdiction |
| Sanctions against Wilma and Gordon | Sanctions improper, no bad faith | Petition groundless, filed in bad faith | Sanctions void; trial court lacked jurisdiction |
| Denial of motion to release documents | Documents should be released | No proper basis for release | Not reached; court lacked jurisdiction |
| Jurisdiction to act | Court retained power to act | Court lost plenary power in 2009 | No jurisdiction after 2009; all subsequent orders void |
Key Cases Cited
- Check v. Mitchell, 758 S.W.2d 755 (Tex. 1988) (court lacks jurisdiction to act after plenary power expires)
- Scott & White Mem’l Hosp. v. Schexnider, 940 S.W.2d 594 (Tex. 1996) (orders issued post-plenary power are void)
- State ex rel. Latty v. Owens, 907 S.W.2d 484 (Tex. 1995) (appellate courts must declare post-plenary orders void)
- Mapco, Inc. v. Forrest, 795 S.W.2d 700 (Tex. 1990) (void judgments are those made without jurisdiction)