Wayne Coughran v. Saddle Brook Apartments

CourtCourt of Appeals of Texas
DecidedFebruary 18, 2004
Docket10-01-00275-CV
StatusPublished

This text of Wayne Coughran v. Saddle Brook Apartments (Wayne Coughran v. Saddle Brook Apartments) 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
Wayne Coughran v. Saddle Brook Apartments, (Tex. Ct. App. 2004).

Opinion

Wayne Coughran v. Saddlebrook Apartments


IN THE

TENTH COURT OF APPEALS


No. 10-01-275-CV


     WAYNE COUGHRAN,

                                                                              Appellant

     v.


     SADDLE BROOK APARTMENTS,

                                                                              Appellee


From the County Court at Law No. 1

McLennan County, Texas

Trial Court # 200101197 CV1

CONCURRING OPINION

      We not only miss the mark in this case, we go far beyond what we need to hold to resolve this case, thereby potentially prejudicing other litigation between these same parties, and compound the complexity of this area of law. To fully understand why our discussion is too broad, a general understanding of the very limited purpose of a forcible detainer action is necessary. Justice Sue LaGarde provided such a discussion and analysis in Rice v. Pinney. Rice v. Pinney, 51 S.W.3d 705, 709-712 (Tex. App.—Dallas 2001, no pet.). In Rice, Justice LaGarde reviews at length the nature of a forcible detainer action, or an FED, as it is commonly referred to in practice. I find no fault with her extensive analysis and quote from it at length.

Nature of a Forcible Detainer Action

The procedure to determine the right to immediate possession of real property, if there was no unlawful entry, is the action of forcible detainer. Kennedy v. Highland Hills Apartments, 905 S.W.2d 325, 326 (Tex. App.—Dallas 1995, no writ). A forcible detainer action is a special proceeding governed by particular statutes and rules. Id. It was created to provide a speedy, simple, and inexpensive means for resolving the question of the right to possession of premises. Id. To preserve the simplicity and speedy nature of the remedy, the applicable rule of civil procedure provides that "the only issue shall be as to the right to actual possession; and the merits of the title shall not be adjudicated." Tex. R. Civ. P. 746; see Johnson v. Fellowship Baptist Church, 627 S.W.2d 203, 204 (Tex. App.—Corpus Christi 1981, no writ). Thus, the sole issue in a forcible detainer suit is who has the right to immediate possession of the premises. Fandey v. Lee, 880 S.W.2d 164, 168 (Tex. App.—El Paso 1994, writ denied); Cuellar v. Martinez, 625 S.W.2d 3, 5 (Tex. Civ. App.—San Antonio 1981, no writ); Johnson v. Highland Hills Drive Apartments, 552 S.W.2d 493, 495 (Tex. Civ. App.—Dallas 1977), writ ref'd n.r.e. per curiam, 568 S.W.2d 661 (Tex. 1978).

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. Goggins, 849 S.W.2d at 377. However, where the right to immediate possession necessarily requires resolution of a title dispute, the justice court has no jurisdiction to enter a judgment and may be enjoined from doing so. Haith v. Drake, 596 S.W.2d 194, 196 (Tex. Civ. App.—Houston [1st Dist.] 1980, writ ref'd n.r.e.); see also Rodriguez v. Sullivan, 484 S.W.2d 592, 593 (Tex. Civ. App.—El Paso 1972, no writ) (justice court judgment void when possession depended on whether defendant complied with contract for deed); Am. Spiritualist Ass'n v. Ravkind, 313 S.W.2d 121, 124 (Tex. Civ. App.—Dallas 1958, writ ref'd n.r.e.) (same). Because a forcible detainer action is not exclusive, but cumulative, of any other remedy that a party may have in the courts of this state, the displaced party is entitled to bring a separate suit in the district court to determine the question of title. Scott v. Hewitt, 127 Tex. 31, 35, 90 S.W.2d 816, 818-19 (1936); Ramirez, 600 S.W.2d at 913; Martinez v. Beasley, 572 S.W.2d 83, 85 (Tex. Civ. App.—Corpus Christi 1978, no writ). Forcible detainer actions in justice courts may be brought and prosecuted concurrently with suits to try title in district court. Haith, 596 S.W.2d at 196; Hartzog v. Seeger Coal Co., 163 S.W. 1055, 1060 (Tex. Civ. App.—Dallas 1914, no writ).

Immediate Possession Determined Separately from Title

Relying exclusively on Mitchell v. Armstrong Capital Corp., 911 S.W.2d 169 (Tex. App.—Houston [1st Dist.] 1995, writ denied), the Rices argue that because their district court suit raised the issue of title to the property, they automatically removed the possession issue from the jurisdiction of the county court at law. According to the Rices, the issues of title to the property and possession of the property are inseparable, and it is unreasonable to determine possession of real estate without first determining who holds its title. We disagree.

Contrary to appellants' assertions, not only can the right to immediate possession be determined separately from the right to title in most cases, but the Texas Legislature purposely established just such a system. In Scott v. Hewitt, the supreme court was asked by certified question to determine whether a provision in a deed of trust that made a defaulted grantor a tenant at sufferance was valid and able to support a forcible detainer action. 90 S.W.2d at 818. After concluding that the provision was valid, the supreme court stated:

If [grantors] desire to attack the sale made under the deed of trust as being invalid, they may bring such suit in the district court for that purpose; but, in a suit for forcible detainer, such action is not permissible. The Legislature has expressly provided by forcible entry and detainer proceedings a summary, speedy, and inexpensive remedy for the determination of who is entitled to the possession of premises,

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Related

Haith v. Drake
596 S.W.2d 194 (Court of Appeals of Texas, 1980)
Kennedy v. Highland Hills Apartments
905 S.W.2d 325 (Court of Appeals of Texas, 1995)
Rice v. Pinney
51 S.W.3d 705 (Court of Appeals of Texas, 2001)
American Spiritualist Ass'n v. Ravkind
313 S.W.2d 121 (Court of Appeals of Texas, 1958)
Mitchell v. Armstrong Capital Corp.
911 S.W.2d 169 (Court of Appeals of Texas, 1995)
Johnson v. Fellowship Baptist Church
627 S.W.2d 203 (Court of Appeals of Texas, 1981)
Cuellar v. Martinez
625 S.W.2d 3 (Court of Appeals of Texas, 1981)
Martinez v. Beasley
572 S.W.2d 83 (Court of Appeals of Texas, 1978)
Johnson v. Highland Hills Drive Apartments
568 S.W.2d 661 (Texas Supreme Court, 1978)
Fandey v. Lee
880 S.W.2d 164 (Court of Appeals of Texas, 1994)
Rodriguez v. Sullivan
484 S.W.2d 592 (Court of Appeals of Texas, 1972)
Johnson v. Highland Hills Drive Apartments
552 S.W.2d 493 (Court of Appeals of Texas, 1977)
Hartzog v. Seeger Coal Co.
163 S.W. 1055 (Court of Appeals of Texas, 1914)
Scott Et Ux. v. Hewitt
90 S.W.2d 816 (Texas Supreme Court, 1936)

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