George E. Saldana v. Carolyn Pena

Texas Court of Appeals, 1st District (Houston)·Decided April 7, 2026·No. 01-24-00271-CV·Published

Opinion

Opinion issued April 7, 2026

In The

Court of Appeals

For The

First District of Texas

This appeal arises from a family law dispute in which appellee Carolyn Pena persuaded the trial court to modify a 2016 order in a suit affecting the parent-child relationship, such that she would now become the minor child’s sole managing conservator. Over the course of time, appellant George E. Saldana filed several recusal motions in this lamentably acrimonious case, including one shortly before the trial setting on Pena’s modification petition. The trial court denied that motion to recuse and proceeded to the modification trial before the regional presiding judge signed a written order denying the recusal motion. Ultimately, the trial court modified the 2016 order, named Pena as the child’s sole managing conservator, and imposed significant restrictions on Saldana’s visitation rights.

In three issues on appeal, Saldana contends that (1) the trial court erred by proceeding with the trial while the recusal motion was pending before the regional presiding judge; (2) he lacked adequate notice of the trial setting; and (3) the trial was fundamentally unfair because he was arrested for allegedly assaulting the court’s bailiff immediately prior to trial, and his incarceration while court was not in session hampered his ability to prepare for trial.

We affirm.

Background

Saldana has represented himself throughout the trial court proceedings and this appeal. Relevant matters started in the 257th District Court of Harris County,

where Saldana filed two recusal motions in October 2021. The trial judge declined to recuse herself voluntarily, and the regional presiding judge denied both recusal motions. Several months later, in June 2022, the trial judge voluntarily recused herself, writing: “There is no Motion to Recuse pending in this matter. However, there have been 2 prior recusal motions filed in this matter. Each has been ruled on and denied by the Presiding Judge of the Eleventh Administrative region.”

The case moved to the 308th District Court of Harris County, where a year passed before the case was transferred again. The case finally landed in the 309th District Court.

As the case approached its preferential setting for the period of October 31 to November 14, 2023, Saldana filed another motion to recuse. The trial judge declined to recuse, and she put the case to a bench trial. Unfortunately, on the day trial was scheduled to begin, something occurred between Saldana and the court bailiff, which resulted in Saldana being jailed on charges of assaulting a public servant. Some of the events were outside the courtroom and thus necessarily not on the record, but some of them took place on the record. Specifically, when Saldana sought to stop the proceedings by citing his pending recusal motion, the judge explained that the tertiary recusal statute allowed the case to carry on.

Saldana maintains in his brief on appeal—apparently based on events either in the hallway or otherwise not taken down by the court reporter—that the recusal

motion must have offended the court bailiff, who retaliated by bringing a posse of fellow bailiffs to put on an aggressive show of force, culminating in Saldana being sent off to jail, which in turn made the ability to prepare for trial less than ideal.

After the trial, the trial court modified the 2016 custody order. The court terminated joint managing conservatorship, named Pena as sole managing conservator, and imposed various restrictions on Saldana, including a requirement that all his visitation with the child be supervised. Saldana then moved for a new trial, contending that (1) the trial was void because of his recusal motion pending before the regional presiding judge; (2) he lacked adequate notice of the trial that began on November 14, 2023; and (3) the trial was generally unfair, largely due to his arrest, which hampered his ability to prepare for trial and present his defense to Pena’s modification petition.

Saldana explains his claim of an unfair trial as follows in his appellate brief, where he gives his version of the first day of trial:

On November 14, 2023, Mr. Saldana was arrested and charged with Assault on a Peace Officer (Bailiff Alderete) involving bodily injury.

Subsequent to his arrest, he was placed in handcuffs and transported to Harris County Jail with a $40,000 bond. Mr. Saldana [w]as found to be indigent and could not afford bail for this alleged serious crime. This procedural failure severely undermines the Appellant’s ability to adequately prepare for trial while incarcerated for an offense he maintains he did not commit.

While awaiting his appearance before the magistrate judge, Mr.

Saldana was informed that he would be bench-warranted back to the 309th District Court . . . .

At this point, Mr. Saldana’s liberty was severely restricted, compelling him to participate in judicial proceedings under duress and without legal counsel. He was returned to the 309th District Court on November 15, 2023, where he faced the same Bailiff Alderete, who had filed the assault allegation against him just one day prior. Despite expressing his disagreement with the proceedings, Mr. Saldana felt he had no choice but to comply, given the authority exerted by the Harris County Sheriff’s Office.

****

Mr. Saldana was mandated by bench warrant to participate in legal proceedings on November 15, 16, and 17. Throughout this period, he was escorted in handcuffs and shackles across various locations within the Harris County Courthouse, including restrooms, under the supervision of Bailiff Alderete. This treatment severely limited and intimidated Mr. Saldana’s ability to prepare adequately for his trial, as he was unable to access his laptop bag, iPhones (X and 14), USB drives, notebooks, and court folders necessary for effective litigation.

These circumstances raise serious concerns regarding the violation of Mr. Saldana’s rights and the integrity of the judicial process. We respectfully request that the court consider these factors as part of this appeal, as they directly impact the fairness of the proceedings and Mr.

Saldana’s ability to defend himself effectively.

We would summarize Pena’s side of the story, were it not for the fact that she has not filed an appellate brief or otherwise appeared in this appeal. Other facts will appear as they become pertinent to the analysis of the issues on appeal.

Recusal of Trial Court Judge In his first issue, Saldana contends that a pending recusal motion obligated the trial court to stand down until the regional presiding judge ruled on the motion. He filed a recusal motion before trial, but the trial court went ahead with the trial anyway, which the recusal rule generally forbids. See TEX. R. CIV. P. 18a(f)(2)(A)

(“If a motion is filed before evidence has been offered at trial, the respondent judge must take no further action in the case until the motion has been decided, except for good cause stated in writing or on the record.”); In re Rio Grande Valley Gas Co., 987 S.W.2d 167, 179 (Tex. App.—Corpus Christi–Edinburg 1999, orig. proceeding) (“Any order other than an order of recusal or referral, entered by a court after a proper motion to recuse is entered is void.”). Thus, Saldana concludes that the trial occurred during a time when the trial court had no jurisdiction.

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George E. Saldana v. Carolyn Pena, (Tex. Ct. App. 2026).

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