Michaela Williams v. Abby Court Apartments, LLC

• Court: Court of Appeals of Texas
• Decided: November 26, 2025
• Docket: 09-25-00059-CV
• Status: Published

Opinion

In The

Court of Appeals

Ninth District of Texas at Beaumont

________________

NO. 09-25-00059-CV ________________

MICHAELA WILLIAMS, Appellant

V.

ABBY COURT APARTMENTS, LLC, Appellee ________________________________________________________________________

On Appeal from the County Court at Law No. 1 Jefferson County, Texas Trial Cause No. 25CCCV0032 ________________________________________________________________________

MEMORANDUM OPINION

Pro se appellant Michaela Williams appealed an eviction and rent arrearage

judgment in favor of appellee Abby Court Apartments, LLC from the Justice of the

Peace Court to the County Court at Law No. 1 of Jefferson County, Texas. She now

appeals the County Court at Law judgment. For the reasons explained below, we

affirm the trial court’s judgment.

1 BACKGROUND

Abby Court obtained a judgment against Williams following a bench trial.

In the judgment, the trial court found in favor of Abby Court and awarded them

possession of the premises, $5,151.08 in past due rent and related costs, and

$1,500.00 in attorney’s fees. The trial court gave Williams seven days to vacate the

premises.

The record shows that the trial court held a bench trial on February 25, 2025.

Williams appeared pro se and Abby Court was represented by counsel. Abby Court

advised the trial court that it sought eviction because Williams defaulted under the

terms of her lease by failing to pay her monthly rental amounts. Williams told the

trial court that they had previously been in court, and she agreed to pay Abby Court

$3,000, but Abby Court objected to this statement and told the trial court that this

was in reference to a failed settlement agreement between the parties. Williams

agreed the parties did not reach a settlement agreement.

Abby Court called Katrina Wright to testify. Wright stated that she is the

regional manager of Ambo Properties which manages Abby Court Apartments.

A copy of Williams’s signed lease agreement was admitted for Apartment 1210

which showed Williams agreed to pay rent of $1,499 per month.1 Wright testified

1 The lease agreement was with Keith Adams and Michaela Williams, but at the time of trial, Adams had vacated the apartment. 2 that at the time of trial, Williams had not paid her rent in a timely manner and was

three months behind. According to Wright, Williams was also responsible for paying

her utilities but had not paid them, and currently her trash, sewer and water were

being billed back to Abby Court. Wright stated that on January 6, 2025, they placed

a 72-hour notice to vacate for nonpayment of rent on Williams’s apartment door,

and a copy of the notice was admitted at trial. They told Williams to vacate by

January 10, 2025. During cross-examination, Wright testified that to her knowledge,

the apartment payment system allows for partial payments.

Williams’s pro se brief does not contain record references, a statement of the

issues presented, or citations to authorities. See Tex. R. App. P. 38.1. Although a

self-represented litigant “is still required to comply with the law and rules of

procedure[,]” we liberally construe pleadings and briefs filed by such a litigant.

Giddens v. Brooks, 92 S.W.3d 878, 880-81 (Tex. App.—Beaumont 2002, pet.

denied). We construe Williams’s brief as challenging the sufficiency of the evidence

regarding her eviction and the rent she was ordered to pay.

In a legal-sufficiency review, we credit favorable evidence if a reasonable

factfinder could, and disregard contrary evidence unless a reasonable factfinder

could not. City of Keller v. Wilson, 168 S.W.3d 802, 827 (Tex. 2005). Evidence is

legally sufficient if it “would enable reasonable and fair-minded people to reach the

verdict under review.” Id. The factfinder is the sole judge of the credibility of the

3 witnesses and is responsible for resolving any conflicts in the evidence, weighing

the evidence, and drawing reasonable inferences from basic facts to ultimate facts.

Id. at 819–21; Sw. Bell Tel. Co. v. Garza, 164 S.W.3d 607, 625 (Tex. 2004). In a

factual-sufficiency review, we consider and weigh all of the evidence, and we will

set aside the trial court’s finding only if the evidence is so weak or the finding is so

against the great weight and preponderance of the evidence that it is clearly wrong

and unjust. See Dow Chem. Co. v. Francis, 46 S.W.3d 237, 242 (Tex. 2001).

As long as the evidence falls within the zone of reasonable disagreement,

we cannot substitute our judgment for that of the factfinder. See City of Keller,

168 S.W.3d at 822.

A forcible detainer action is governed by discrete provisions of the Texas

Property Code and the Texas Rules of Civil Procedure. See Tex. Prop. Code Ann.

§§ 24.001–.011; Tex. R. Civ. P. 510.1–.13. “The action is intended to be a summary,

speedy, and inexpensive remedy for resolving a dispute over ‘who is entitled to

possession of the premises.’” McClane v. New Caney Oaks Apartments, 416 S.W.3d

115, 118 (Tex. App.—Beaumont 2013, no pet.) (citation omitted).

The elements of a landlord’s cause of action for forcible detainer are:

(1) a landlord-tenant relationship exists between the parties; (2) the tenant can be

evicted because he is a holdover tenant, tenant at will, tenant at sufferance, or the

tenant of a person who acquired possession by forcible entry; (3) the landlord made

4 a proper demand for possession; (4) the period of time to vacate the property has

expired; and (5) the tenant has refused to surrender possession to the landlord.

See Tex. Prop. Code Ann. § 24.002; Murphy v. Countrywide Home Loans, Inc.,

199 S.W.3d 441, 445 (Tex. App.—Houston [1st Dist.] 2006, pet. denied). Although

the only issue to be determined is the right to actual possession, a claim for rent may

be brought with the action. See Murphy, 199 S.W.3d at 446–47 (discussing forcible

detainer as determining a superior right to immediate ownership); see also Tex. R.

Civ. P. 510.3(a), (d) (stating that a claim for rent may be asserted in an eviction case),

510.8(b) (stating required contents of judgment, including delinquent rent, if

applicable). “To prevail in a forcible detainer action, a plaintiff is not required to

prove title, but is only required to show sufficient evidence of ownership to

demonstrate a superior right to immediate possession.” Rice v. Pinney, 51 S.W.3d

705, 709 (Tex. App.—Dallas 2001, no pet.).

Crediting favorable evidence if a reasonable factfinder could and disregarding

contrary evidence unless a reasonable factfinder could not, we conclude that the

evidence would enable reasonable and fair-minded people to conclude that Abby

Court was entitled to possession and was owed rent in the amount determined by the

trial court. Therefore, the evidence was legally sufficient. See City of Keller,

168 S.W.3d at 827. Furthermore, considering and weighing all the evidence, we

conclude that the evidence that Abby Court was entitled to possession and was owed

5 rent in the amount determined by the trial court is not so weak nor are the findings

so against the great weight and preponderance of the evidence as to be clearly wrong

and unjust. See Francis, 46 S.W.3d at 242. Therefore, the evidence is factually

sufficient. Accordingly, we overrule Williams’s issues and affirm the trial court’s

judgment.

AFFIRMED.

KENT CHAMBERS Justice

Submitted on November 4, 2025 Opinion Delivered November 26, 2025

Before Golemon, C.J., Wright and Chambers, JJ.