Richard Kirby v. Benny Fletcher

CourtCourt of Appeals of Texas
DecidedAugust 15, 2024
Docket12-23-00279-CV
StatusPublished

This text of Richard Kirby v. Benny Fletcher (Richard Kirby v. Benny Fletcher) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Richard Kirby v. Benny Fletcher, (Tex. Ct. App. 2024).

Opinion

NO. 12-23-00279-CV

IN THE COURT OF APPEALS

TWELFTH COURT OF APPEALS DISTRICT

TYLER, TEXAS

RICHARD KIRBY, § APPEAL FROM THE 241ST APPELLANT

V. § JUDICIAL DISTRICT COURT

BENNY FLETCHER, APPELLEE § SMITH COUNTY, TEXAS

MEMORANDUM OPINION

Richard Kirby, proceeding pro se, appeals following the trial court’s order awarding sanctions against him and in favor of Appellee Benny Fletcher and dismissing his suit. Kirby raises two issues on appeal. We affirm.

BACKGROUND Kirby was a tenant on property owned by Fletcher by virtue of a lease between Agrinomics, LLC and Fletcher. Separately, the parties entered into a “Farm and Ranch Contract,” by which Agrinomics, LLC sought to purchase the property from Fletcher. That contract stated that the lease agreement would terminate upon default of the purchase contract. After a period of years, when the purchase contract did not close, Fletcher demanded that Kirby and his wife vacate the premises. Kirby, who contended that Fletcher was responsible for addressing certain alleged deficiencies of the property, filed the instant suit in the 241st Judicial District Court of Smith County, Texas against Fletcher, by which he sought relief pursuant to Title 8, Chapter 92 of the Texas Property Code 1 and asked the court to order Fletcher to “cease and desist any further demands or attempts to evict [him] from the property.” Days later, Fletcher filed suit in Justice Court, Precinct 5, of Smith County Texas to evict Kirby from the property. Following a hearing, the Justice Court ordered Kirby to vacate the premises and entered judgment in Fletcher’s favor. Kirby appealed the Justice Court’s order to the County Court at Law of Smith County, Texas for a trial de novo. There, Kirby filed a plea to the jurisdiction, in which he argued that the Justice Court lacked jurisdiction to entertain the eviction suit in light of his pending petition for relief in the underlying case. The court denied his plea to the jurisdiction and, ultimately, entered judgment in Fletcher’s favor. Kirby appealed the County Court at Law’s judgment to this court. We dismissed the appeal due to Kirby’s failure to comply with Texas Civil Practice and Remedies Code, Section 51.017. 2 Kirby filed a petition for review with the Texas Supreme Court, which was denied. Following our dismissal of Kirby’s appeal, the County Court at Law issued a writ of possession and ordered the clerk of the court to issue the writ in accordance with its final judgment. Kirby appealed this order. We dismissed Kirby’s appeal because we determined we lacked jurisdiction to review the trial court’s order issuing a writ of possession because it was not a final judgment or an otherwise appealable order. 3 Kirby filed a petition for review with the Texas Supreme Court, which was dismissed for want of jurisdiction. Thereafter, Kirby filed a petition for writ of mandamus in this court, in which he argued that the County Court at Law abused its discretion by refusing to rule on his plea to the jurisdiction when it had reasonable time to do so. See In re Kirby, No. 12-21-00191-CV, 2021 WL 5500524, at *2 (Tex. App.–Tyler Nov. 23, 2021, no pet.) (mem. op.). In his plea, Kirby argued that the Justice Court lacked jurisdiction to entertain Fletcher’s eviction petition because the action he filed in the District Court was filed first and involved the same parties. See id. In support of his argument, he contended that Texas Property Code, Sections 92.006, 92.052, and 92.331 prevented the Justice Court and County Court at Law from exercising jurisdiction when Fletcher had been

1 See, e.g., TEX. PROP. CODE ANN. §§ 92.006, 92.061, 92.331 (West 2023). 2 See Kirby v. Fletcher, No. 12-21-00146-CV, 2021 WL 4313862, at *1 (Tex. App.–Tyler Sept. 22, 2021, pet. denied) (mem. op). 3 Kirby v. Fletcher, No. 12-21-00160-CV, 2021 WL 5118410, at *2 (Tex. App.–Tyler Nov. 3, 2021, pet. dism’d w.o.j.) (mem. op.).

2 served with a notice of repairs, and the Justice Court and County Court at Law cannot exercise jurisdiction when the property was under contract between the parties. See id. In denying Kirby’s petition, we held that Kirby’s arguments were heard and denied by the County Court at law, both explicitly by order and implicitly in the court’s final judgment. See id. We further held that Kirby conceivably could challenge the implicit denial of his plea on appeal from the County Court at Law’s final judgment. 4 See id. Kirby did not appeal our denial of his petition for writ of mandamus to the Texas Supreme Court. In the underlying suit, as it pertains to this appeal, after filing an answer, Fletcher filed a motion for sanctions against Kirby pursuant to Texas Civil Practice and Remedies Code, Chapter 10, 5 to which Kirby filed a response. Following an evidentiary hearing on the matter, the trial court granted Fletcher’s motion for sanctions, awarded attorney’s fees as sanctions against Kirby in the amount of $12,775.00, and dismissed his suit. This appeal followed.

THE JUSTICE COURT’S AND COUNTY COURT AT LAW’S JURISDICTION In his first issue, Kirby seeks to collaterally attack the judgment and writ of possession of the County Court at Law because, as he contends, the underlying cause of action deprived the Justice Court and the County Court at Law of jurisdiction over Fletcher’s eviction suit. Inadequate Briefing Although Kirby is proceeding pro se, he still is held to the same standards as a licensed attorney and must comply with all applicable rules of procedure; otherwise, he would benefit from an unfair advantage over parties represented by counsel. See Kirby v. Fletcher, No. 12-21-00146-CV, 2021 WL 4313862, at *1 n.1 (Tex. App.–Tyler Sept. 22, 2021, pet. denied) (mem. op). In the briefing of his first issue, Kirby does little more than state legal propositions with citations to authority. He provides no citations to the record, nor does he seek to apply the facts to the legal authority he cites, so as to provide any substantive analysis of his claim. Accordingly, Kirby’s first issue is inadequately briefed and presents nothing for our review. See

4 We noted that the appeal of this case was dismissed due to Kirby’s failure to comply with Texas Civil Practice and Remedies Code, Section 51.017(a). See In re Kirby, No. 12-21-00191-CV, 2021 WL 5500524, at *2 (Tex. App.–Tyler Nov. 23, 2021, no pet.) (mem. op.). Thus, we held that because Kirby had not acted diligently to protect his rights, he could not use mandamus as a substitute for an appeal, even though the appellate remedy no longer was available. See id. 5 See TEX. CIV. PRAC. & REM. CODE ANN. §§ 10.001–10.005 (West 2017).

3 J.C. Gen. Contractors v. Chavez, 421 S.W.3d 678, 682 (Tex. App.–El Paso 2014, pet. denied) (citing TEX. R. APP. P. 38.1(i)). As such, because Kirby’s brief lacked the necessary components of a clear and concise argument, we could decline to reach the merits of his first issue. See Chavez, 421 S.W.3d at 682. But even had Kirby adequately briefed his first issue, the outcome would not differ. Concurrent Jurisdiction for Forcible Detainer Actions In his first issue, Kirby argues that according to specified legal precedent, the justice court and county court at law did not have jurisdiction to resolve the forcible detainer action against him because the cause of action in the underlying case deprives the other courts of jurisdiction. 6 Whether a court has subject-matter jurisdiction is a question of law, which we review de novo. Wagner v. D’Lorm, 315 S.W.3d 188, 191 (Tex. App.–Austin 2010, no pet.).

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Richard Kirby v. Benny Fletcher, Counsel Stack Legal Research, https://law.counselstack.com/opinion/richard-kirby-v-benny-fletcher-texapp-2024.