in Re: Rent Space Mgmt LLC

Court of Appeals of Texas·Decided July 5, 2022·No. 05-22-00460-CV·Published

Opinion

Conditionally Granted and Opinion Filed July 5, 2022

In the Court of Appeals Fifth District of Texas at Dallas No. 05-22-00460-CV

IN RE RENT SPACE MGMT LLC, Relator

Original Proceeding from the County Court at Law No. 1 Dallas County, Texas Trial Court Cause No. CC-21-04670-A

MEMORANDUM OPINION Before Justices Schenck, Reichek, and Carlyle Opinion by Justice Carlyle In this mandamus proceeding, relator Rent Space Mgmt LLC seeks to compel

the trial court to issue a writ of possession regarding certain real property in Dallas

County (the Property). Though this Court requested responses from real party in

interest Tyra Goodley and the respondent, no response was filed. After reviewing

Rent Space’s mandamus petition and the mandamus record, we conditionally grant

the petition for writ of mandamus.

Background

In July 2021, Rent Space filed suit in justice court to evict Ms. Goodley from

the Property. A jury found in Rent Space’s favor and the justice court entered a judgment awarding Rent Space possession of the Property. Ms. Goodley appealed in

county court. Though a trial date was set, the county court instead entered a

December 2021 abatement order sua sponte.

Rent Space successfully challenged the abatement order in a prior mandamus

proceeding in this Court, In re Rent Space Mgmt LLC, No. 05-21-01073-CV, 2022

WL 248075 (Tex. App.—Dallas Jan. 27, 2022, orig. proceeding) (mem. op.). Then,

the trial court vacated the abatement order, conducted a trial regarding the eviction

proceeding, and entered a February 22, 2022 final judgment awarding Rent Space

possession of the Property. The judgment ordered “that Plaintiff shall be entitled to,

and the Clerk of this Court is so directed to issue, all writs of execution and other

process that are necessary to enforce this final judgment, including a writ of

possession, which may issue on March 7, 2022, for which let execution issue.”

On February 23, 2022, Ms. Goodley filed (1) a voluntary Chapter 13

bankruptcy proceeding in federal bankruptcy court, see 11 U.S.C. §§ 301, 1301–30,

and (2) a notice in the trial court asserting that the bankruptcy filing “automatically

stays certain collection and other actions against the debtor and the debtor’s property

including the debtor’s possession of the property at issue.”

On March 7, 2022, with the bankruptcy proceeding pending, Rent Space paid

the trial court clerk the fee required for issuance and execution of a writ of possession

on the Property. Rent Space also filed a motion in the bankruptcy court asking that

–2– court to “confirm” the applicability of an exception to the bankruptcy code’s

automatic stay provision. The record shows no ruling on that motion.

On April 13, 2022, Rent Space filed a “Motion Demanding Award of Writ of

Possession” in the trial court. The motion asked the trial court to authorize issuance

and execution of a writ of possession or, alternatively, enter an order extending the

time to issue a writ of possession to 90 days after entry of the final judgment. The

next day, the trial court coordinator sent the parties an email stating the trial court

“would need to see some instruction from the bankruptcy court that we are able to

proceed” and “[u]ntil we receive such instruction, our case is stayed.”

A week later, Ms. Goodley filed a voluntary motion to dismiss the bankruptcy

proceeding. The bankruptcy court signed an April 26, 2022 order granting the

requested dismissal “with prejudice against refiling for 180 days.” That same day,

Rent Space notified the trial court of the bankruptcy proceeding’s dismissal and

requested that the trial court issue a writ of possession pursuant to the February 22,

2022 final judgment. In an April 28, 2022 email to the parties, the trial court noted

that “[m]ore than 60 days have passed since the judgment was signed in this case”

and requested briefing by the next day on “the issue of whether the bankruptcy stay

extends the 60-day period when the writ may issue.”

Rent Space filed an April 29, 2022 “Motion for Issuance of Writ of Possession

More than 60 Days after Judgment” asking the trial court to issue the writ of

possession on two grounds: (1) the bankruptcy proceeding operated as a stay of

–3– issuance of the writ of possession and (2) Texas Rule of Civil Procedure 510.8

authorized the trial court to extend the deadline from 60 days to 90 days for good

cause. Rent Space also emailed the trial court on April 29, May 3, and May 6

requesting a prompt ruling on that motion. The trial court did not rule on Rent

Space’s motion or issue a writ of possession.

On May 13, 2022, Rent Space filed this mandamus proceeding. Rent Space

also filed a May 16, 2022 motion for emergency stay, asserting, “On May 23, 2022,

90 days will have passed since the trial court entered its Final Judgment awarding

possession of the Property to Relator. On May 26, 2022, 30 days will have passed

since Defendant’s bankruptcy proceeding—and any stay under § 362 of the

bankruptcy code—terminated.” This Court issued a May 18, 2022 order staying all

trial court proceedings pending resolution of Rent Space’s mandamus petition.

Analysis

To obtain mandamus relief, the relator must show that the trial court clearly

abused its discretion and the relator has no adequate appellate remedy. In re Copart,

Inc., 619 S.W.3d 710, 713 (Tex. 2021) (orig. proceeding) (per curiam) (citing In re

Prudential Ins. Co. of Am., 148 S.W.3d 124, 135–36 (Tex. 2004) (orig. proceeding)).

“A clear abuse of discretion occurs when the trial judge errs in analyzing or applying

the law to the facts or the trial judge has but one reasonable decision and does not

make that decision.” In re Dyer Custom Installation, Inc., 133 S.W.3d 878, 880 (Tex.

App.—Dallas 2004, orig. proceeding).

–4– Texas Rule of Civil Procedure 510.8(d) provides that if the judgment in an

eviction case is in the plaintiff’s favor, “the judge must award a writ of possession

upon demand of the plaintiff and payment of any required fees.” TEX. R. CIV. P.

510.8(d). Though a writ of possession generally “may not issue more than 60 days

after a judgment for possession is signed,” “[f]or good cause, the court may extend

the deadline for issuance to 90 days after a judgment for possession is signed.” Id.

510.8(d)(1). “A writ of possession may not be executed after the 90th day after a

judgment for possession is signed.” Id. 510.8(d)(2). On appeal to the county court,

the writ of possession is to be issued and executed as in other cases. Id. 510.13.

A voluntary bankruptcy petition “operates as a stay” of proceedings against

the debtor, subject to limited exceptions. See 11 U.S.C. § 362(a)–(b). The stay

terminates upon dismissal of the bankruptcy case. Id. § 362(c).

When applicable, bankruptcy code § 108(c) “extends certain deadlines for

thirty days after notice of the termination of a bankruptcy stay.” Brashear v. Victoria

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