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Henderson v. O'Neill

Supreme Court of Texas
Oct 31, 1990
797 S.W.2d 905 (Tex. 1990)

Summary

holding that mandamus was appropriate remedy where trial court ruled on motion to transfer without giving sufficient notice, made no attempt to follow the rule, and acknowledged deviating from the rule

Summary of this case from In re Foust

Opinion

No. D-0321.

October 31, 1990.

Aubrey B. Calvin, Michael C. Clark, Sue V. Speck, Bradley L. DeLuca, Houston, for relator.

C.E. Clover, Sealy, for respondent.


This is a mandamus proceeding. Henderson sought mandamus relief after the trial court sustained a motion for transfer of venue without providing advance notice. His underlying cause of action alleges breach of contract, deceptive trade practices and fraudulent misrepresentation in relation to the sale of a radio station. Henderson also sought temporary injunctive relief to compel the real parties in interest to lease a transmitter site needed for operation of the radio station. The issue of venue was determined immediately before Henderson's request for injunctive relief which was set on the ancillary docket pursuant to local rules. Henderson objected to the transfer of venue based on, among other contentions, the lack of notice required under Texas Rule of Civil Procedure 87. He also filed two motions requesting that the trial court reconsider its order which were both denied. Because we believe the trial court abused its discretion, the Court conditionally grants the writ.

Texas Rule of Civil Procedure 87 specifies that the movant has the duty to request a setting on the motion for transfer of venue. The Rule also provides, "[e]xcept on leave of court each party is entitled to at least 45 days notice of a hearing on the motion to transfer." Tex.R.Civ.P. 87.1. The trial court abused its discretion by ruling on the motion to transfer without giving Henderson sufficient notice. The record indicates that the trial court made no attempt to follow the applicable rule and, in fact, acknowledged its deviation from the required procedure. Under these facts, a writ of mandamus is the appropriate remedy. See Abor v. Black, 695 S.W.2d 564, 567 (Tex. 1985).

Because the trial court's order conflicts with Texas Rule of Civil Procedure 87, a majority of the Court grants leave to file the petition for writ of mandamus and, without hearing oral argument, holds that relator is entitled to a writ of mandamus directing the trial court to vacate its order sustaining the defendants' motion to transfer venue. Tex.R.App.P. 122. The writ shall issue only if the trial court fails to act in accordance with this opinion.


Summaries of

Henderson v. O'Neill

Supreme Court of Texas
Oct 31, 1990
797 S.W.2d 905 (Tex. 1990)

holding that mandamus was appropriate remedy where trial court ruled on motion to transfer without giving sufficient notice, made no attempt to follow the rule, and acknowledged deviating from the rule

Summary of this case from In re Foust

holding that trial court abuses its discretion by ruling on motion to transfer venue without giving parties required notice

Summary of this case from In re D.J.M.

holding mandamus appropriate when venue transferred without proper notice to parties under rules of civil procedure

Summary of this case from In re Fincher

concluding that mandamus was an appropriate remedy for the trial court's failure to follow applicable venue procedure in ruling on a motion to transfer venue without providing advance notice

Summary of this case from In re K2 Waste Sol., LLC

concluding that mandamus was an appropriate remedy for the trial court's failure to follow applicable venue procedure in ruling on a motion to transfer venue without providing advance notice

Summary of this case from In re Lowe's Home Ctrs., L.L.C.

In Henderson v. O'Neill, 797 S.W.2d 905 (Tex. 1990) (per curiam), we held that it is an abuse of discretion, correctable by mandamus, for a trial court to rule on a motion to transfer venue without giving the parties the notice required by TEX.R.CIV.P. 87, subd. 1.

Summary of this case from HCA Health Services of Texas, Inc. v. Salinas

In Henderson, the supreme court held that the relator was "entitled to a writ of mandamus directing the trial court to vacate its order sustaining the defendants’ motion to transfer venue" because the trial court signed its order without giving the relator sufficient notice as required by Rule 87. Henderson, 797 S.W.2d at 905 (emphasis added).

Summary of this case from In re Rino-K&K Compression, Inc.
Case details for

Henderson v. O'Neill

Case Details

Full title:Roy E. HENDERSON, Relator, v. The Honorable Jack O'NEILL, Judge, Respondent

Court:Supreme Court of Texas

Date published: Oct 31, 1990

Citations

797 S.W.2d 905 (Tex. 1990)

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