In Re Elizabeth Thomas v. the State of Texas

• Court: Texas Court of Appeals, 1st District (Houston)
• Decided: June 23, 2026
• Docket: 01-26-00619-CV
• Status: Published

Opinion

Opinion issued June 23, 2026

In The

Court of Appeals For The

First District of Texas ———————————— NO. 01-26-00619-CV ——————————— IN RE ELIZABETH THOMAS, Relator

Original Proceeding on Petition for Writ of Mandamus

MEMORANDUM OPINION

Relator Elizabeth Thomas, acting pro se, filed a petition for writ of mandamus

challenging the county court’s June 6, 2026 order dismissing her underlying action

for failing to obtain prefiling permission after having been declared a vexatious

litigant.1 See TEX. CIV. PRAC. & REM CODE §§ 11.102(a), 11.1035(b). Although the

1 The underlying case is Elizabeth Thomas v. Worth National Title Company, LLC D/B/A McKnight Title, Worth National Insurance Company, and Naga V. Tran, cause number 1277047, pending in the County Civil Court at Law No. 5 of Harris County, Texas, the Honorable Jermaine Thomas presiding. mandamus petition is directed at the county court, Relator also challenges the

November 16, 2023 order of the 80th District Court of Harris County declaring her

a vexatious litigant by asserting that the county court should have disregarded the

order.2 We deny the petition.

PER CURIAM Panel consists of Justices Guerra, Gunn, and Morgan.

2 The vexatious litigant order was issued in James Allen and Allan Haye v. P.C.F. Properties in TX, LLC v. Elizabeth Thomas, James M. Andersen, and JPMorgan Chase Bank, N.A., No. 2020-35780 (80th Dist. Ct., Harris County, Tex., Nov. 16, 2023). See Office of Court Administration, List of Vexatious Litigants Subject to a Pre-Filing Order, https://www.txcourts.gov/judicial-data/vexatious-litgants/ (last visited June 19, 2026). 2