James Patrick Cullinan v. Jenevieve Marie Mata

CourtTexas Court of Appeals, 4th District (San Antonio)
DecidedJanuary 21, 2026
Docket04-24-00770-CV
StatusPublished

This text of James Patrick Cullinan v. Jenevieve Marie Mata (James Patrick Cullinan v. Jenevieve Marie Mata) is published on Counsel Stack Legal Research, covering Texas Court of Appeals, 4th District (San Antonio) primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
James Patrick Cullinan v. Jenevieve Marie Mata, (Tex. Ct. App. 2026).

Opinion

Fourth Court of Appeals San Antonio, Texas MEMORANDUM OPINION

No. 04-24-00770-CV

James Patrick CULLINAN, Appellant

v.

Jenevieve Marie MATA, Appellee

From the County Court At Law No. 10, Bexar County, Texas Trial Court No. 2024CV00181 Honorable David J. Rodriguez, Judge Presiding

Opinion by: Irene Rios, Justice

Sitting: Irene Rios, Justice Lori Massey Brissette, Justice Adrian A. Spears II, Justice

Delivered and Filed: January 21, 2026

AFFIRMED

Appellant James Patrick Cullinan appeals the trial court’s judgment awarding appellee

Jenevieve Mata the right to recover possession of a dog they acquired while they were in a romantic

relationship. On appeal, Cullinan contends the evidence is legally and factually insufficient to

support the trial court’s judgment awarding Mata possession of the dog. We conclude the evidence

is sufficient to support the trial court’s implicit finding that Cullinan converted the dog and the

trial court’s judgment awarding Mata possession of the dog. We affirm. 04-24-00770-CV

BACKGROUND

Mata and Cullinan began a romantic relationship in 2015. The dog that is the subject of

this appeal was adopted in December 2019. Mata and Cullinan ended their relationship sometime

in 2020 or 2021. 1 Although Mata maintained possession of the dog after her relationship with

Cullinan ended, there were times the dog would stay with Cullinan. At some point while Cullinan

had possession of the dog, he refused to return the dog to Mata because, according to Cullinan, he

was concerned with the dog’s wellbeing due to Mata’s lifestyle. In August 2023, Mata filed suit

in justice court to reclaim possession of the dog. The justice court rendered judgment in Mata’s

favor finding she was the owner of the dog. Cullinan appealed the justice court’s judgment to the

county court at law, which we refer to as the trial court. After a de novo bench trial, the trial court

rendered judgment that Mata shall recover the dog from Cullinan. Cullinan appeals.

STANDARD OF REVIEW

When findings of fact and conclusions of law are not requested following a bench trial, the

reviewing court implies all necessary findings to support the judgment. Shields Limited

Partnership v. Bradberry, 526 S.W.3d 471, 480 (Tex. 2017). Because the reporter’s record has

been filed in this appeal, the legal and factual sufficiency of the trial court’s implied findings may

be challenged in the same manner as jury findings or a trial court’s express findings of fact. Id.

When an appellant challenges the legal sufficiency of the evidence on adverse findings for

which the appellant did not have the burden of proof, the appellant must show there is no evidence

to support the adverse findings. Eagle Rock Timber, Inc. v. Rock Hard Rental, LLC, 672 S.W.3d

438, 448 (Tex. App.—San Antonio 2023, pet. denied). We view the evidence in the light most

favorable to the findings, disregarding all contrary evidence that a reasonable factfinder could have

1 The parties dispute the year the relationship ended. Mata testified the relationship ended in 2020, and Cullinan testified the relationship ended in 2021.

-2- 04-24-00770-CV

disbelieved. Id. “If there is more than a scintilla of evidence to support a finding, it must be

upheld.” Id.

If the appellant attacks the factual sufficiency of the evidence supporting an adverse finding

on an issue for which the appellant did not bear the burden of proof, then the appellant must show

the finding is so contrary to the overwhelming weight of the evidence as to be clearly wrong and

manifestly unjust. Id. “In a factual sufficiency review, we consider and weigh all the evidence.”

Id. (citing Cain v. Bain, 709 S.W.2d 175, 176 (Tex. 1986)).

“In a bench trial, the trial court, as the factfinder, is the sole judge of the credibility of the

witnesses and the weight to be given their testimony.” Alonso v. Alvarez, 409 S.W.3d 754, 757

(Tex. App.—San Antonio 2013, pet. denied). “In resolving factual disputes, the trial court can

accept or reject any part or all of a witness’s testimony.” Id. “The trial court may believe one

witness and disbelieve others and resolve[] any inconsistencies in a witness’s testimony.” Id.

CONVERSION

In Cullinan’s sole issue he asserts that the evidence is legally and factually insufficient to

support the trial court’s judgment that Mata is entitled to recover possession of the dog. Mata

represented herself pro se in the trial court and what we construe as her pleadings are not a model

of clarity. However, the trial court stated on the record that this case was tried by consent on the

pleadings and categorized the cause of action asserted as one for conversion of the dog. Therefore,

we construe Cullinan’s sole issue on appeal as a challenge to the trial court’s implicit finding that

Cullinan converted the dog.

Although countless Texas families view their pets as family members, for over a century

pets have been labeled as “property” for purposes of tort-law recovery. Strickland v. Medlen, 397

S.W.3d 184, 188 (Tex. 2013). “The term ‘property’ is not a pejorative but a legal descriptor, and

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its use should not be misconstrued as discounting the emotional attachment that pet owners

undeniably feel.” Id. at 186.

“Conversion is the unauthorized and unlawful assumption and exercise of dominion and

control over the personal property of another to the exclusion of, or inconsistent with, the owner’s

rights.” Freezia v. IS Storage Venture, LLC, 474 S.W.3d 379, 386 (Tex. App.—Houston [14th

Dist.] 2015, no pet.) (citing Waisath v. Lack’s Stores, Inc., 474 S.W.2d 444, 446 (Tex. 1971)). To

establish a claim for conversion of personal property, a plaintiff must show that (1) the plaintiff

owned, had legal possession of the property, or was entitled to possession of the property; (2) the

defendant unlawfully and without authorization assumed and exercised dominion and control over

the property to the exclusion of, or inconsistent with the plaintiff’s rights; and (3) the defendant

refused the plaintiff’s demand to return the property. Longaker v. Evans, 32 S.W.3d 725, 732 (Tex.

App.—San Antonio 2000, pet. withdrawn). A plaintiff who establishes conversion is entitled to

either the return of the property along with damages for its loss of use during the time of its

detention or the value of the property. Wiese v. Pro Am Servs., Inc., 317 S.W.3d 857, 862 (Tex.

App.—Houston [14th Dist.] 2010, no pet.).

Regarding the first conversion element—that Mata owned or was entitled to possession of

the dog—Mata testified she adopted the dog in 2019 and identified the adoption agency she used

to adopt the dog. Mata stated she went through the adoption process with a friend. Importantly,

Mata testified that she paid for the adoption fees. Mata testified she and Cullinan agreed that all

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Related

Carla Strickland v. Kathryn and Jeremy Medlen
397 S.W.3d 184 (Texas Supreme Court, 2013)
Waisath v. Lack's Stores, Inc.
474 S.W.2d 444 (Texas Supreme Court, 1971)
Longaker v. Evans
32 S.W.3d 725 (Court of Appeals of Texas, 2000)
Wiese v. Pro Am Services, Inc.
317 S.W.3d 857 (Court of Appeals of Texas, 2010)
Cain v. Bain
709 S.W.2d 175 (Texas Supreme Court, 1986)
Freezia v. IS Storage Venture, LLC
474 S.W.3d 379 (Court of Appeals of Texas, 2015)
Shields Ltd. Partnership v. Bradberry
526 S.W.3d 471 (Texas Supreme Court, 2017)

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James Patrick Cullinan v. Jenevieve Marie Mata, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-patrick-cullinan-v-jenevieve-marie-mata-txctapp4-2026.