Shamar D. Bradley v. the Connor Group, Julie Bray Patterson, and Roberto A. Vazquez

• Court: Texas Court of Appeals, 4th District (San Antonio)
• Decided: May 20, 2026
• Docket: 04-25-00482-CV
• Status: Published

Opinion

Fourth Court of Appeals San Antonio, Texas MEMORANDUM OPINION No. 04-25-00482-CV

Shamar D. BRADLEY, Appellant

v.

THE CONNOR GROUP, Julie Bray Patterson, and Roberto A. Vazquez, Appellees

From the County Court at Law No. 3, Bexar County, Texas Trial Court No. 2025-CV-01071 Honorable Lisa Jarrett, Judge Presiding

PER CURIAM

Sitting: Rebeca C. Martinez, Chief Justice Irene Rios, Justice Velia J. Meza, Justice

Delivered and Filed: May 20, 2026

DISMISSED AS MOOT

This interlocutory appeal arises from a suit against Judge Julie Bray Patterson 1 and Judge

Roberto A. Vasquez. 2 Because the appellant has filed a notice of nonsuit abandoning all claims,

we dismiss the appeal as moot.

1 Bexar County Justice of the Peace Precinct 3, Place 1. 2 Bexar County Justice of the Peace Precinct 2, Place 1. 04-25-00482-CV

DISCUSSION

“We are obligated to consider our jurisdiction at all times,” and we lack jurisdiction when

no live controversy remains. Morath v. Lewis, 601 S.W.3d 785, 788 (Tex. 2020) (per curiam).

Mootness is a component of subject-matter jurisdiction that we review de novo. Sw. Elec. Power

Co. v. Lynch, 595 S.W.3d 678, 682 (Tex. 2020). A case becomes moot when the parties no longer

have a “personal stake in the outcome,” that is, a “concrete interest, however small.” Tex. Dep’t of

Family & Protective Servs. v. Grassroots Leadership, Inc., 717 S.W.3d 854, 875 (Tex. 2025)

(quoting Campbell-Ewald Co. v. Gomez, 577 U.S. 153, 161 (2016)).

On February 7, 2025, Shamar D. Bradley sued Judge Patterson, alleging “official

oppression and abuse of authority” arising from an eviction proceeding. After Judge Patterson

recused, the case was transferred to Judge Vasquez, whom Bradley then joined as a defendant.

Both judges filed a plea to the jurisdiction asserting governmental immunity, which the trial court

granted. Bradley filed a notice of interlocutory appeal on July 11, 2025. He later filed a notice

nonsuiting “all claims herein asserted by Shamar D. Bradley.”

We ordered Bradley to show cause why the appeal should not be dismissed as moot. In

response, he contends the nonsuit is ineffective because it was not served on appellees and that his

motion for sanctions remains pending.

A nonsuit is effective when filed and extinguishes the case or controversy as to the

nonsuited claims, rendering interlocutory orders on the merits moot. Univ. of Tex. Med. Branch at

Galveston v. Estate of Blackmon, 195 S.W.3d 98, 100–01 (Tex. 2006) (per curiam). Service is not

required for the nonsuit to take effect. Orion Invs., Inc. v. Dunaway & Assocs., Inc., 760 S.W.2d

371, 374 (Tex. App.—Fort Worth 1988, writ denied).

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This interlocutory appeal concerns only the trial court’s ruling on appellees’ immunity. See

TEX. CIV. PRAC. & REM. CODE § 51.014(a)(8). Because Bradley has nonsuited all claims against

appellees, no live controversy remains regarding that ruling. A pending sanctions request does not

preserve a justiciable interest in the interlocutory order from which Bradley is appealing.

Accordingly, we dismiss this appeal as moot. See Speer v. Presbyterian Children’s Home & Serv.

Agency, 847 S.W.2d 227, 228 (Tex. 1993). All pending motions are denied.

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