Limitations, Notice, and Equity in Collateral Attacks on Tax Foreclosure Sales: Thompson v. Landry (Tex. 2025)

Limitations, Notice, and Equitable Defenses in Collateral Attacks on Tax Foreclosure Sales:
A Commentary on Cindy Thompson v. Mae Landry, Supreme Court of Texas (May 9, 2025)

I. Introduction

This opinion from the Supreme Court of Texas clarifies the relationship between:

  • constitutional due process limits on tax foreclosure judgments, and
  • statutory limitations and equitable defenses available to protect subsequent purchasers.

The case arises from a tax foreclosure suit filed in 2004 against several owners of a twelve‑acre tract in Chambers County. The taxing authorities served the record owner (the grandmother) by publication under Texas Rule of Civil Procedure 117a, and in 2005 obtained a default judgment. In 2006, Cindy Thompson purchased the property at the ensuing tax sale and received a constable’s deed in February 2007, which was recorded on February 9, 2007.

The respondent, Mae Landry, had inherited her grandmother’s interest in the land but was never listed as record owner. She had lived on the property her whole life, including after the tax sale. In 2009, her husband signed a lease with Thompson’s husband for the property containing their mobile home, and they paid rent.

Nearly eleven years after the default judgment—and more than ten years after the constable’s deed was recorded—Landry filed suit (in 2018) collaterally attacking the 2005 tax judgment on due process grounds. She contended that service by publication on her deceased grandmother violated Rule 117a and the Fourteenth Amendment, making the judgment void and the tax sale to Thompson legally ineffective.

The trial court agreed, set aside the tax judgment, declared Thompson’s deed void, and vested title in Landry. The court of appeals reversed, holding there were fact issues on whether the taxing authorities exercised reasonable diligence before resorting to publication, but it rejected Thompson’s limitations and equitable defenses at the summary‑judgment stage.

The Supreme Court of Texas granted Thompson’s petition for review on two questions that Mitchell v. MAP Resources, Inc.1 had left unresolved:

  1. Whether a former owner’s actual notice of a default tax judgment or tax sale within the statutory limitations and redemption period bars a later collateral attack against a subsequent purchaser.
  2. Whether a subsequent purchaser may assert equitable defenses—notably laches and the Restatement (Second) of Judgments § 66—when the former owner delays suing after learning of the judgment or sale, even if that notice came after limitations expired.

The Court answers both questions in the purchaser’s favor as matters of doctrine, but finds that the summary‑judgment record does not conclusively establish when Landry learned of the tax sale or Thompson’s ownership. It therefore affirms the remand ordered by the court of appeals and sends the case back for fact‑finding.

II. Summary of the Opinion

A. The Court’s Core Holdings

The Supreme Court establishes three key principles:

  1. Notice within limitations defeats a collateral attack against a purchaser.
    A property owner may not set aside a subsequent purchaser’s deed on due process grounds if the owner obtained actual notice of the default tax judgment or the tax sale during the statutory two‑year limitations and redemption period in Tax Code §§ 33.54 and 34.21. In that circumstance, the owner had an adequate legal remedy (to redeem or sue) and cannot bypass limitations by styling the lawsuit as a due‑process‑based collateral attack.
  2. Equitable defenses are available even where notice arrives after limitations.
    A subsequent purchaser may assert equitable defenses—particularly the kind described in In re E.R.2 and Restatement (Second) of Judgments § 66—against a collateral attack on a void judgment where:
    • the former owner, after receiving actual notice of the judgment or sale, manifests an intention to treat the judgment as valid (for example, by paying rent to the purchaser); and
    • setting aside the judgment would impair the purchaser’s substantial reliance interests (for example, taxes paid, improvements made).
    This extends the equitable boundary principles from the parental-termination context (E.R.) to tax foreclosure and property title disputes.
  3. On this record, timing of notice is a fact question.
    Thompson did not conclusively establish when Landry learned of the tax sale or of Thompson’s ownership:
    • the constable’s deed was recorded February 9, 2007;
    • the written lease offered in evidence is dated August 3, 2009 (outside the two‑year statutory window); and
    • Landry’s testimony was not precise about when she first realized they were paying rent to the new owner.
    Because the date of Landry’s notice remains disputed, the Court holds:
    • Thompson is not entitled to summary judgment on limitations; and
    • Thompson is not entitled to summary judgment on her equitable defenses.

B. Issues Left for the Trial Court on Remand

Importantly, the Supreme Court does not decide whether Landry’s due process rights were actually violated in the 2005 tax suit. The court of appeals had already held that fact issues exist regarding the taxing authorities’ diligence before resorting to service by publication under Rule 117a, and Landry did not cross‑petition to challenge that aspect of the appellate judgment. As a result, on remand the trial court must resolve:

  • Did the taxing authorities exercise reasonable diligence in attempting personal service?
  • Was service by publication (posting) constitutionally adequate under Mitchell, Mullane, and In re E.R.?
  • When did Landry obtain actual notice of:
    • the default tax judgment, or
    • the tax sale and Thompson’s claim of ownership?
  • Based on that timing and subsequent conduct, do limitations or laches (or related equitable doctrines) bar Landry’s requested relief against Thompson?

III. Doctrinal Background

A. Tax Foreclosure Procedure and Service under Rule 117a

Texas Rule of Civil Procedure 117a governs service of citation in delinquent ad valorem tax suits. Its core features:

  • Personal service is the default rule. For Texas residents, the rule requires personal service unless the defendant qualifies for citation by publication under subdivision 3.
  • Citation by publication or posting is a last resort.
    Rule 117a(3) allows publication—via newspaper or, if not feasible, posting on the courthouse door—only if the taxing unit’s attorney swears that the owner’s name or residence is unknown and cannot be ascertained after diligent inquiry.
  • Diligent inquiry is required.
    Consistent with Sgitcovich v. Sgitcovich,3 parties may not resort to substituted or constructive service when reasonable diligence would produce the information necessary for personal service.

After judgment, the property may be sold at a tax foreclosure sale. The purchaser receives a constable’s deed, which is recorded in the county real property records. The Texas Tax Code then provides:

  • A two‑year limitations period to sue the tax purchaser.
    Tax Code § 33.54 bars “action[s] relating to the title to property” against a tax-sale purchaser after:
    • two years from the date the purchaser’s deed is recorded, if the property was the owner’s homestead on the date the underlying tax suit was filed.
  • A two‑year right of redemption for a residence homestead.
    Under Tax Code § 34.21(a), an owner may redeem a homestead property sold at a tax sale within two years after the purchaser’s deed is recorded by paying the purchaser the amount bid plus specified statutory add‑ons.

These statutes create a defined period in which a former owner who knows about the sale can either:

  • file suit to challenge the purchaser’s title; or
  • redeem the property by reimbursement.

B. Due Process, Void Judgments, and Collateral Attacks

Under the federal Due Process Clause, “notice and opportunity for hearing appropriate to the nature of the case” are required before the government deprives a person of property.4 The seminal case Mullane v. Central Hanover Bank & Trust Co.5 holds that notice must be “reasonably calculated, under all the circumstances, to apprise interested parties of the pendency of the action.” Actual notice is preferred, but constructive notice may suffice if personal service is not reasonably available.

When service fails to comply with due process, any resulting default judgment is void:

  • The court lacks personal jurisdiction over the unserved defendant.
  • The judgment can be attacked at any time, directly or collaterally, unless equitable defenses bar relief.

A collateral attack is a lawsuit brought in a new action seeking to declare a prior judgment void or ineffective. Unlike a direct appeal or bill of review, it challenges the foundational validity of the judgment itself, often on jurisdictional or constitutional grounds.

C. Mitchell v. MAP Resources, Inc. (2022)

In Mitchell, the Court held that heirs of mineral-interest owners could collaterally attack a 1999 tax foreclosure judgment obtained through citation by posting on the courthouse door, where:

  • the record contained no evidence of diligent inquiry to locate the heirs; and
  • the heirs’ addresses were readily ascertainable from public records.

The Court concluded that a “complete failure of service deprives a litigant of due process and a trial court of personal jurisdiction; the resulting judgment is void and may be challenged at any time.”6 It allowed a collateral attack outside the Tax Code’s two‑year limitations period.

However, Mitchell explicitly left two questions open:

  • whether limitations or laches might bar relief where the plaintiffs had actual notice of the judgment or sale and failed to act; and
  • whether equitable doctrines like laches could ever defeat a notice‑based collateral attack.

Mitchell noted the record there was “devoid” of evidence about how or when the plaintiffs learned of the judgment, so it did not resolve those questions.7

D. In re E.R. (2012) and the Restatement’s Boundary on Attacking Void Judgments

In re E.R. involved termination of parental rights obtained through service by publication, with a statutory six‑month deadline for filing a restricted appeal. This Court held:

  • service by publication was invalid because more diligent efforts at personal service were required; and
  • the statutory six‑month deadline did not bar a collateral attack on the void termination order.

Yet the Court also made clear that even void judgments are not eternally vulnerable in all circumstances. Quoting Restatement (Second) of Judgments § 66, it recognized that equitable principles may bar an attack where:

  1. after receiving actual notice of the judgment, the person manifests an intention to treat the judgment as valid; and
  2. granting relief would impair another’s substantial reliance interest on the judgment.8

In E.R. itself, the record did not show when the parent learned of the judgment, so the case was remanded for fact‑finding—just as in Thompson v. Landry.

IV. The Court’s Legal Reasoning in Thompson v. Landry

A. Two Very Different Kinds of Notice

The opinion draws an important distinction between:

  1. Notice of the underlying tax suit
    This is the classic due process question: did the taxing authorities use methods reasonably calculated to inform the owner of the pending foreclosure? If not, the default judgment is void for lack of personal jurisdiction. That is the question governed by Rule 117a, Mullane, Mitchell, and E.R..
  2. Notice of the judgment or the tax sale (and thus of the due process violation)
    This concerns when the owner—or the owner’s successor—actually learns that:
    • a tax foreclosure judgment has been entered, and/or
    • the property has been sold and a purchaser claims ownership.
    This second kind of notice determines whether:
    • the owner had an adequate legal remedy within the statutory limitations and redemption period, and
    • equitable defenses like laches or § 66 of the Restatement may bar relief.

The trial court and court of appeals primarily focused on the first type of notice (was service proper?). The Supreme Court’s opinion addresses chiefly the second, because those are the only issues preserved in the petition for review.

B. Effect of Notice within the Tax Code Limitations Period

The Court holds that if a property owner obtains actual notice of divestment—of either the default judgment or the tax sale—within the two‑year window following recordation of the constable’s deed, the owner cannot later sue the purchaser outside that window and escape the statute by arguing due process.

The reasoning proceeds as follows:

  1. Statutory framework creates an adequate legal remedy.
    If the owner learns during the two‑year period that the homestead has been sold at tax sale, Tax Code §§ 33.54 and 34.21 give her:
    • a cause of action against the purchaser to contest title, and
    • a statutory right to redeem the property by reimbursing the purchaser.
    Those remedies are legal in nature and presumptively adequate.
  2. Where an adequate legal remedy exists, equity does not intervene.
    Citing LaSalle Bank National Ass'n v. White,9 the Court reiterates that equitable remedies are unavailable when an adequate remedy at law exists. Once the owner has notice in time to use statutory remedies, due process does not require courts to undo the purchaser’s deed outside the limitations period.
  3. Mitchell is narrowed and clarified.
    The court of appeals had read Mitchell to mean that the limitations statute is always “irrelevant” when a collateral attack is based on defective service. The Supreme Court rejects that reading:
    • Limitations is “irrelevant” only when the owner did not obtain actual notice of the judgment or sale during the limitations period. In that scenario, the owner did not have a meaningful opportunity to use statutory remedies, so due process permits a later collateral attack on the void judgment.
    • If the owner had timely notice, the Tax Code’s limitations and redemption scheme controls; the owner cannot disregard it merely because the original service was constitutionally defective.

In short, the Court harmonizes Mitchell with the Tax Code by conditioning the “limitations is irrelevant” statement on the absence of timely notice of the adverse judgment or sale.

C. Extension of Equitable Defenses to the Tax Foreclosure Context

The second major holding concerns the availability of equitable defenses to a collateral attack on a void judgment. The Court adopts, for property and tax matters, the Restatement § 66 framework previously invoked in In re E.R.:

“[A] party may not challenge an invalid default judgment if
  1. after receiving actual notice of the judgment, she manifested an intention to treat the judgment as valid; and
  2. granting relief would impair another person's substantial interest of reliance on the judgment.”10

This equitable limitation mirrors traditional Texas laches doctrine: “unreasonable delay” in asserting rights, coupled with “disadvantage” or prejudice to the opposing party (as outlined in Rogers v. Ricane Enterprises, Inc.11 and Culver v. Pickens12).

Under the Court’s reasoning:

  • A former owner who learns of the tax sale (even after limitations has expired), and then:
    • pays rent to the purchaser,
    • permits the purchaser to pay taxes, invest in improvements, or otherwise rely on the judgment and deed, and
    • waits years before filing suit
    may be barred from relief by laches or § 66, because it would be inequitable to upset the purchaser’s entrenched reliance.
  • These equitable defenses do not “validate” the void judgment in a technical jurisdictional sense, but they limit the availability of equitable relief against innocent purchasers and protect the finality of property transactions.

D. Application to Thompson’s Summary Judgment Motions

1. Limitations Defense

Thompson argued that Landry knew of the tax sale and Thompsons’ ownership within the two‑year window following recordation of the constable’s deed (February 9, 2007 to February 9, 2009). If true, Landry’s 2018 suit would be barred by Tax Code § 33.54.

The evidence Thompson offered:

  • Landry and her husband lived on the property the entire time.
  • A written lease dated August 3, 2009, between Landry’s husband and Thompson’s husband, showing:
    • Thompson’s side acting as landlord/owner;
    • the Landrys agreeing to pay rent; and
    • Landry’s testimony acknowledging that she knew her husband was paying rent.

The problem, as the Court points out, is timing:

  • The lease itself is outside the two‑year limitations period (dated August 3, 2009).
  • Landry’s testimony is not clear about when she first understood they were renting from the Thompsons as owners; it does not conclusively place that awareness before February 9, 2009.

Therefore, the summary‑judgment record does not conclusively show that Landry had notice of Thompson’s asserted ownership within the two‑year period. Thompson thus failed to establish her limitations defense as a matter of law, and summary judgment on that ground was properly denied.

2. Equitable Defenses (Laches / § 66 of the Restatement)

Thompson also invoked laches and equitable estoppel, arguing:

  • Landry knew she was paying rent to the Thompsons as early as 2009;
  • the Thompsons continued to pay property taxes and act as owners from 2007 onward; and
  • Landry waited until 2018—eleven years after recordation of the deed—to file suit.

The Supreme Court agrees that such an argument is legally available in a tax foreclosure case, extending the E.R./Restatement framework beyond parental-rights judgments. But as with limitations, the timing and nature of Landry’s notice remain unclear:

  • There is no conclusive evidence of when Landry personally understood that:
    • her title had been extinguished by a tax judgment, or
    • the Thompsons claimed fee simple ownership, as distinct from some lesser arrangement.
  • Without a firm date of actual notice, the Court cannot determine as a matter of law that her delay was “unreasonable” or that she knowingly “stood mute” while Thompson relied on the judgment.

As in In re E.R., the absence of clear evidence about when the complaining party learned of the judgment precludes summary judgment on equitable grounds. The issue must go to the factfinder on remand.

V. Clarifying Key Legal Concepts

A. Collateral Attack vs. Direct Attack

  • A direct attack (appeal, motion for new trial, bill of review) challenges a judgment in the same case or through court‑prescribed mechanisms, usually within strict time limits.
  • A collateral attack arises in a new lawsuit and argues that the prior judgment is void—typically for lack of jurisdiction or fundamental due process—so it cannot be given effect.

Collateral attacks are normally disfavored, but they are permitted where, as here, the claim is that the court never had personal jurisdiction due to constitutionally inadequate service.

B. Constructive Notice vs. Actual Notice

  • Actual notice means the party truly knew—through receipt of documents, conversations, or other direct information—about the suit, judgment, or sale.
  • Constructive notice is a legal fiction: the law treats a party as having notice because the information was published or recorded in a way that should have come to their attention (e.g., newspaper publication, posting at the courthouse, recordation of a deed).

For due process, constructive notice is permissible only when personal service is not reasonably feasible. For limitations and equitable defenses in this context, the Court is focused on actual notice—when the owner truly knew of the sale or claim of ownership.

C. Void vs. Voidable Judgments

  • A void judgment is a legal nullity: the court lacked jurisdiction to render it (for example, because of a complete failure of service). It can be attacked at any time, subject to equitable limitations like § 66 of the Restatement.
  • A voidable judgment is erroneous but was rendered by a court with jurisdiction. It is binding unless timely challenged by appropriate direct means.

The Thompson opinion accepts, consistent with Mitchell and E.R., that a judgment rendered after a complete failure of proper service is void. The new wrinkle is that even a void judgment may be practically immune from collateral attack against an innocent purchaser where statutory remedies were available but not used, or where equitable defenses apply after the former owner learns of the judgment and stands by.

D. Laches and Equitable Estoppel Simplified

  • Laches bars a claim when:
    1. There is an unreasonable delay in asserting a known right; and
    2. The delay causes prejudice—a detrimental change of position—by the opposing party.
  • Equitable estoppel is similar but focuses on misleading conduct: a party’s behavior leads another, in good faith, to change position; it then becomes inequitable to allow the first party to assert a contrary right.

In this case, the Restatement § 66 framework functions as a specialized laches rule for void judgments: if, after learning of the void judgment, the former owner acts like it is valid and allows others to rely on it, equity may bar undoing that judgment later.

VI. Precedents Cited and Their Influence

A. Due Process and Notice Cases

  • Mullane v. Central Hanover Bank & Trust Co., 339 U.S. 306 (1950) – baseline due process standard for notice.
  • Jones v. Flowers, 547 U.S. 220 (2006) – government must take additional steps if it learns prior notice efforts failed.
  • Dusenbery v. United States, 534 U.S. 161 (2002) – due process does not require heroic efforts; reasonable methods suffice.
  • In re E.R., 385 S.W.3d 552 (Tex. 2012) – invalid service by publication in parental termination case; collateral attack allowed; introduces Restatement § 66 boundary.
  • Mitchell v. MAP Resources, Inc., 649 S.W.3d 180 (Tex. 2022) – establishes that a complete failure of diligent service in a tax foreclosure suit renders the judgment void and subject to collateral attack; clarified here.
  • Gill v. Hill, 688 S.W.3d 863 (Tex. 2024); B. Gregg Price, P.C. v. Series 1 – Virage Master LP, 661 S.W.3d 419 (Tex. 2023) – restate modern due process notice principles and reinforce the need for constitutionally adequate notice.

B. Service and Diligence

  • Sgitcovich v. Sgitcovich, 241 S.W.2d 142 (Tex. 1951) – no resort to substituted service when diligent efforts would produce information for personal service; used here to interpret Rule 117a’s diligence requirement.

C. Limitations, Equity, and Remedies

  • LaSalle Bank Nat’l Ass’n v. White, 246 S.W.3d 616 (Tex. 2007) – equitable remedies apply only when there is no adequate remedy at law; central to the Court’s conclusion that equitable collateral attacks are unnecessary (and barred) when the owner had timely statutory remedies.
  • Rogers v. Ricane Enters., Inc., 772 S.W.2d 76 (Tex. 1989); Culver v. Pickens, 176 S.W.2d 167 (Tex. 1943) – define laches as unreasonable delay plus prejudice; provide the doctrinal basis for transplanting laches principles into this tax foreclosure collateral attack context.
  • Restatement (Second) of Judgments § 66 (1982) – supplies the two‑prong test limiting challenges to void judgments when there is detrimental reliance and post‑notice acquiescence by the challenger; explicitly adopted in E.R. and extended here.

D. Procedural and Contextual Cases

  • In re Thompson, 569 S.W.3d 169 (Tex. App.—Houston [1st Dist.] 2018, orig. proceeding) – earlier mandamus proceeding in this same dispute, holding that the trial court lacked authority to set aside the 2005 tax judgment through intervention in the original case years after it became final; shaped the procedural posture leading to this separate 2018 collateral-attack suit.
  • Valence Operating Co. v. Dorsett, 164 S.W.3d 656 (Tex. 2005) – states cross‑motion for summary judgment standard of review: de novo consideration of all evidence and issues, rendering the judgment the trial court should have rendered.

Collectively, these authorities support the Court’s blend of:

  • strict enforcement of due process requirements in obtaining default tax judgments, and
  • robust protection of finality and reliance interests in real property titles once an owner has had a fair opportunity to respond or has knowingly acquiesced after learning of the judgment.

VII. Impact and Practical Implications

A. For Property Owners Facing Tax Foreclosure

This decision does not weaken the due process standards governing tax foreclosures. If taxing authorities fail to exercise reasonable diligence in identifying and serving the true owner, the resulting judgment may still be void and subject to collateral attack, as in Mitchell.

But the opinion imposes two critical constraints:

  1. If an owner learns about the judgment or tax sale during the statutory two-year period, she must act within that period—by suing under § 33.54 or redeeming under § 34.21—or risk losing the ability to recover the property from the purchaser.
  2. Even if she first learns of the tax sale after the period expires, she must act diligently thereafter. Unreasonable delay, especially when combined with conduct that acknowledges the purchaser’s ownership (such as renting the property), may lead to laches or equitable estoppel.

The practical message to property owners: once you know your property has been sold at a tax sale—even if you think that sale was constitutionally defective—you must act quickly and consistently with your claimed rights.

B. For Subsequent Purchasers at Tax Sales

The decision substantially strengthens the legal position of good-faith tax-sale purchasers:

  • Purchasers can now argue that a former owner’s actual notice of the sale or judgment within the statutory window bars late-filed suits, even when service was unconstitutional.
  • They can also invoke equitable defenses—especially laches and the Restatement § 66 standard—when owners wait years after learning of the sale and behave in ways that treat the judgment as valid.
  • Title to tax-sale properties is therefore more secure, reducing the risk that a long-past service defect will upset settled expectations where the prior owner had a fair chance to act or later knowingly acquiesced.

C. For Litigators and Trial Courts

This opinion reorients fact development and summary-judgment strategy in service-defect cases involving property transfers:

  • The timing and nature of the former owner’s knowledge will be a focal point:
    • When did the owner first learn of the judgment or tax sale?
    • How did she learn—through eviction notices, recording information, conversations, or documents like leases?
    • What did she do afterward—did she pay rent, acknowledge the new owner, or simply remain silent?
  • Purchasers and their counsel will be well served to gather documentary and testimonial evidence showing:
    • owner’s early awareness of the sale,
    • owner’s conduct consistent with recognizing the sale’s validity, and
    • purchaser’s reliance (tax payments, improvements, refinancing, etc.).
  • Trial courts evaluating motions for summary judgment should be skeptical of such motions where the record is incomplete on the notice timeline, just as the Supreme Court was here.

D. Doctrinal Significance: Finality of Void Judgments

Perhaps the most far-reaching doctrinal implication is the Court’s willingness to impose meaningful limits on collateral attacks even on void judgments, at least where third-party reliance and statutory remedies are involved. This continues a trend seen in In re E.R.:

  • While void judgments remain vulnerable to attack on jurisdictional grounds, the scope of available relief is controlled by:
    • statutory limitations and redemption schemes; and
    • equitable doctrines that protect reliance interests and discourage strategic delay.

That balance is particularly important in the real-property context, where stability of recorded titles and reliance by purchasers are essential.

VIII. Conclusion

The Supreme Court of Texas’s decision in Cindy Thompson v. Mae Landry does not dilute the constitutional requirement of diligent, reasonably calculated service in tax foreclosure suits. Instead, it clarifies that:

  1. Owners who receive actual notice of a tax judgment or sale during the statutory limitations and redemption period cannot later evade those statutory deadlines by invoking due process. They had an adequate legal remedy and must use it within the time the Legislature provided.
  2. Even where notice comes later, equitable defenses are available to protect good-faith purchasers. If a former owner learns of the void judgment, acts as though it is valid, and allows substantial reliance to accrue, laches and the Restatement § 66 limitation may preclude setting the judgment aside.
  3. Factual questions about the timing and character of notice are often outcome-determinative. Here, because the record does not clearly show when Landry learned of the sale or of Thompson’s ownership, neither limitations nor laches could be resolved as a matter of law, and the case is properly remanded for trial.

In doctrinal terms, the opinion harmonizes Mitchell’s robust protection of due process with the Tax Code’s limitations and redemption scheme, and extends the equitable approach of In re E.R. to property and tax foreclosure disputes. It thus marks an important precedent in Texas property and judgment law: safeguarding owners against constitutionally defective tax foreclosures, while protecting subsequent purchasers from belated challenges when owners had notice and an opportunity—statutory or equitable—to act.

1. Mitchell v. MAP Resources, Inc., 649 S.W.3d 180 (Tex. 2022).
2. In re E.R., 385 S.W.3d 552 (Tex. 2012).
3. Sgitcovich v. Sgitcovich, 241 S.W.2d 142 (Tex. 1951).
4. Gill v. Hill, 688 S.W.3d 863, 867 (Tex. 2024) (quoting Jones v. Flowers, 547 U.S. 220 (2006)).
5. 339 U.S. 306 (1950).
6. Mitchell, 649 S.W.3d at 194.
7. Id. at 197.
8. In re E.R., 385 S.W.3d at 567 (quoting Restatement (Second) of Judgments § 66).
9. 246 S.W.3d 616 (Tex. 2007).
10. In re E.R., 385 S.W.3d at 567.
11. 772 S.W.2d 76 (Tex. 1989).
12. 176 S.W.2d 167 (Tex. 1943).

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