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Spence et al. v. Hersom — Appeal Dismissed Moot, Judgment Vacated

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Summary

Andrew Spence and Cassie Alexander appealed an adverse eviction judgment from the County Court at Law No. 2 of Johnson County, Texas (Trial Court Cause No. CC-C20230567). Upon confirming to the Court Clerk that they are no longer in possession of the property, the Tenth Appellate District of Texas vacated the trial court's judgment and dismissed the appeal as moot on April 23, 2026, also dismissing all pending motions.

“Accordingly, because Appellants are no longer in possession of the premises in question, we vacate the trial court's judgment and dismiss the case as moot.”

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About this source

The Texas Courts of Appeals are intermediate appellate courts that hear every appeal from Texas district and county courts before cases reach the Texas Supreme Court or Court of Criminal Appeals. Together they publish around 290 opinions a month across civil, criminal, family, probate, and administrative cases. Texas's economy and legal volume mean the courts generate significant precedent on energy, oil and gas, commercial real estate, employment, and family law that affects multistate clients. GovPing tracks every published opinion via CourtListener's mirror, with case name, parties, court division, and outcome. Watch this if you litigate in Texas, advise on energy or land disputes, or track how Texas courts treat federal questions in commercial cases.

What changed

The appellate court vacated the trial court's eviction judgment and dismissed the appeal because the appellants were no longer in possession of the premises, rendering the appeal moot. The court cited Texas Property Code § 24.004(a) (justice court eviction jurisdiction) and Texas Rule of Civil Procedure 510.3 (limiting eviction cases to the right to actual possession).

For parties involved in eviction proceedings, this decision underscores that appellate courts cannot grant meaningful relief once the appellant no longer possesses the property. Counsel and litigants should ensure continued possession during the pendency of any appeal to preserve appellate jurisdiction; loss of possession during appeal typically renders the dispute moot and ends the court's ability to adjudicate the merits.

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Apr 24, 2026

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April 23, 2026 Get Citation Alerts Download PDF Add Note

Andrew Spence and Cassie Alexander v. Georgia E. Hersom

Texas Court of Appeals, 10th District (Waco)

Disposition

Dismissed as moot

Lead Opinion

Court of Appeals
Tenth Appellate District of Texas

10-24-00181-CV

Andrew Spence and Cassie Alexander,
Appellants

v.

Georgia E. Hersom,
Appellee

On appeal from the
County Court at Law No. 2 of Johnson County, Texas
Judge F. Steven McClure, presiding
Trial Court Cause No. CC-C20230567

CHIEF JUSTICE JOHNSON delivered the opinion of the Court.

MEMORANDUM OPINION

Andrew Spence and Cassie Alexander appealed from a de novo judgment

from the county court at law in an eviction proceeding. The Appellants had

appealed an adverse decision from the justice court to the county court at law.

Upon request by the Clerk of this Court as to whether or not Appellants were

still in possession of the property in question, Appellants have informed this
Court that they are no longer in possession of the property, do not dispute that

this appeal is moot, and “do not oppose dismissal of the appeal on that basis.”

Chapter 24 of the Texas Property Code grants justice courts "jurisdiction

in eviction suits," including suits for forcible entry and detainer and forcible

detainer. TEX. PROP. CODE ANN. § 24.004(a). Texas Rule of Civil Procedure

510.3, which governs eviction cases, identifies "the right to actual possession"

as the "[o]nly [i]ssue" in an eviction case and specifies that claims "not asserted

because of this rule can be brought in a separate suit in a court of proper

jurisdiction." TEX. R. CIV. P. 510.3(e).

Accordingly, because Appellants are no longer in possession of the

premises in question, we vacate the trial court's judgment and dismiss the case

as moot. Appellants’ pending motions are also dismissed as moot.

MATT JOHNSON
Chief Justice

OPINION DELIVERED and FILED: April 23, 2026
Before Chief Justice Johnson,
Justice Smith, and
Justice Harris
Appeal dismissed;
Judgment vacated;
Motions dismissed
CV06

Spence v. Hersom Page 2

Named provisions

Jurisdiction in Eviction Suits Only Issue

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Source document text, dates, docket IDs, and authority are extracted directly from TX 10th App.

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Last updated

Classification

Agency
TX 10th App
Filed
April 23rd, 2026
Instrument
Enforcement
Branch
Judicial
Legal weight
Binding
Stage
Final
Change scope
Minor
Document ID
10-24-00181-CV
Docket
10-24-00181-CV

Who this affects

Applies to
Landlords Tenants
Industry sector
5311 Real Estate
Activity scope
Eviction proceedings Appeals Property possession disputes
Geographic scope
Texas US-TX

Taxonomy

Primary area
Judicial Administration
Operational domain
Legal
Topics
Real Estate

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