Jeremy Harlow v. Tara Thompson

• Court: Court of Appeals of Texas
• Decided: June 11, 2025
• Docket: 03-24-00287-CV
• Status: Published

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN

NO. 03-24-00287-CV

Jeremy Harlow, Appellant

v.

Tara Thompson, Appellee

FROM COUNTY COURT AT LAW NO. 3 OF COMAL COUNTY NO. 2024CV0078, THE HONORABLE DEBORAH WIGINGTON, JUDGE PRESIDING

MEMORANDUM OPINION

Jeremy Harlow, appearing pro se, appeals from the trial court’s final judgment

rendered in favor of Tara Thompson after a bench trial on her breach-of-contract and breach-of-

warranty claims. Thompson initially sued Harlow in justice court for damages after he allegedly

built a faulty patio for her. After the justice court rendered judgment for Thompson, Harlow

appealed to the county court. Obtaining an unfavorable judgment at the county court, Harlow

perfected this appeal.

On appeal, Harlow challenges the sufficiency of the evidence to support the

judgment. However, Harlow did not request a reporter’s record, and thus no reporter’s record

was filed in this Court. See Tex. R. App. P. 34.6(b) (providing that it is appellant’s responsibility

to request reporter’s record). In the absence of a reporter’s record, we must presume that the trial

court heard sufficient evidence to make all necessary findings in support of its judgment. Bennett v. Cochran, 96 S.W.3d 227, 230 (Tex. 2002); De Leon v. De Leon, No. 03-15-00027-

CV, 2016 WL 4506783, at *1 (Tex. App.—Austin Aug. 24, 2016, no pet.) (mem. op.); see also

Tex. R. App. P. 37.3(c) (if no reporter’s record is filed due to appellant’s fault, appellate

court may consider those issues that do not require reporter’s record). Harlow’s evidentiary-

sufficiency issues—which comprise all his issues on appeal—require a review of the reporter’s

record, which is not before us. Consequently, he has not shown reversible error, and we affirm

the trial court’s judgment.1

__________________________________________ Karin Crump, Justice

Before Justices Theofanis, Crump, and Ellis

Affirmed

Filed: June 11, 2025

1 We recognize that Harlow has attempted to represent himself in this proceeding, but we must apply the same substantive and procedural standards to him as we do to litigants represented by counsel, lest we afford him an unfair advantage merely because he is pro se. See Mansfield State Bank v. Cohn, 573 S.W.2d 181, 184–85 (Tex. 1978). 2