Johnny Tyson II v. Warren Inn Haltom City Ltd. D/B/A Acacia Apartments

In the Court of Appeals Second Appellate District of Texas at Fort Worth ___________________________ No. 02-25-00679-CV ___________________________ JOHNNY TYSON II, Appellant V. WARREN INN HALTOM CITY LTD. D/B/A ACACIA APARTMENTS, Appellee On Appeal from County Court at Law No. 1 Tarrant County, Texas Trial Court No. 2025-005600-1 Before Birdwell, Bassel, and Wallach, JJ. Memorandum Opinion by Justice Birdwell  MEMORANDUM OPINION Appellant Johnny Tyson II, proceeding pro se, appeals a judgment in a forcible-detainer suit in which the trial court (1) ordered that Appellee Warren Inn Haltom City, Ltd. d/b/a Acacia Apartments was entitled to possession of an apartment that he had leased and (2) awarded Warren Inn past-due rent and attorney’s fees. Because Tyson has been evicted from the apartment, the possession issue is moot. Because Tyson has inadequately briefed any issues independent of possession, he has waived those issues. Accordingly, we vacate the judgment in part and affirm in part. I. Background Tyson leased an apartment—the property at issue—from Warren Inn with a lease term from November 1, 2024, to October 31, 2025. For several months during the lease term, Warren Inn charged Tyson a late fee for failing to pay rent on time. When Tyson failed to pay rent in June 2025 or to comply with a notice to vacate the apartment, Warren Inn filed a forcible-detainer suit in the justice court. The justice court signed a judgment for Warren Inn, awarding possession of the apartment, delinquent rent, and costs. Tyson appealed the justice court’s judgment to the county court at law (the trial court). The justice-court transcript was filed in the trial court on July 23, 2025. Tyson represented himself and filed several pro se documents in the trial court: (1) “Plea in Abatement and Verified Order to Show Cause”; (2) “Request for Judicial Notice of 2 Constitutional Law, Federal Recognition, Scripture, and Maxims of Equity”; (3) “Verified Affidavit of Status and Right”; (4) “Verified Affidavit of Misnomer”; (5) “Verified Affidavit of Truth”; (6) “Affidavit of Non-Consent to Jurisdiction and Special Appearance”; (7) “Affidavit of Harm, Fraud, and Trespass Upon the Living Man”; (8) “Affidavit of Ecclesiastical Standing and Jurisdiction”; (9) “Statement of Cause for Appeal and Verified Demand to Abate for Want of Jurisdiction”; (10) “Verified Objection to Unlawful Appearance, Motion to Strike Counsel, and Motion to Stay Proceedings Pending Ruling on Verified Plea in Abatement”; (11) “Verified Notice of Hearing Requested on Equity Matters and Verified Objections”; and (12) “Verified Answer, Affirmative Defenses, Counterclaims, and Declaration of Intent.” On August 8, 2025, the trial court signed an order setting a nonjury trial for August 27, 2025, at 1:30 p.m. Tyson did not appear at trial. The trial court considered the testimony and evidence and awarded Warren Inn possession of the apartment, past-due rent, and attorney’s fees. It signed its judgment on August 27, 2025. The same day, Tyson filed a notice of removal to the United States District Court for the Northern District of Texas, and the case was transferred to that court. After the case was transferred to federal court, Tyson continued filing pro se documents and requests in the trial court, including a “Public Bond Tender”; a “Field Notice of Bond Tender, Trustee Appointment, and Possession Stay Notice to Enforcement Officer/Constable”; a “Request for Writ”; and various other filings. 3  On November 13, 2025, the federal court remanded the case back to the trial court. On November 20, 2025, the trial court signed an order extending the issuance and execution of the writ of possession per its August 27, 2025 judgment, and a writ of possession was issued on December 1, 2025. Tyson timely filed his notice of appeal on December 4, 2025, but absent his filing a bond superseding the judgment, the writ of possession was subsequently executed on December 5, 2025. II. Discussion Tyson appeals the trial court’s August 27, 2025 judgment without challenging any specific award to Warren Inn. He does not specifically challenge the award of past-due rent and attorney’s fees. In several disjointed, overlapping, hard-to-decipher arguments, Tyson challenges the issuance of the writ of possession based on the August 27, 2025 judgment. A. The Possession Issue is Moot As a preliminary matter, we address whether this appeal is moot because Tyson has been evicted from the apartment. 1 A case becomes moot if, at any stage of the proceedings, a controversy ceases to exist between the parties. See Marshall v. Hous. Auth. of San Antonio, 198 S.W.3d 782, 1 Tyson acknowledges the eviction. In his brief, he states that when the writ of possession was executed, “[t]he constable removed [him] from his home during a rainstorm” and that he “was rendered homeless” and “was forced to live in a friend’s automobile, then in a rented storage unit, and is currently residing in a group home.” Warren Inn does not dispute the fact Tyson has been evicted, so we accept it as true. See Tex. R. App. P. 38.1(g); Sherman v. Hillcrest Apartments, No. 02-25-00053-CV, 2025 WL 2989761, at *1 n.1 (Tex. App.—Fort Worth Oct. 23, 2025, no pet.). 4 787 (Tex. 2006). “The only issue in a forcible[-]detainer action is the right to actual possession of the premises.” Id. at 785. Thus, a forcible-detainer appeal becomes moot upon an appellant’s eviction from the property unless (1) the appellant holds and asserts a meritorious claim of right to current, actual possession of the property or (2) damages or attorney’s fees remain at issue. See id. at 787; Sherman, 2025 WL 2989761, at *2. Here, because Tyson has been evicted from the apartment, the possession issue is moot unless he holds and asserts a meritorious claim of right to current, actual possession of the apartment. See Marshall, 198 S.W.3d at 787; Sherman, 2025 WL 2989761, at *2. The apartment lease has expired—as of October 31, 2025—and Tyson presents no basis for claiming a right to possession after the lease’s expiration.2 See Marshall, 198 S.W.3d at 787. Tyson’s appeal as to the issue of possession of the apartment is therefore moot. See Sherman, 2025 WL 2989761, at *2; Devilbiss v. Burch, No. 04-16-00711-CV, 2018 WL 2418476, at *2 (Tex. App.—San Antonio May 30, 2018, pet. denied). 2 In his brief, Tyson addresses the issue of mootness, but he does so in the context of an original proceeding that he filed in this court: “Even though [he] sought emergency relief from this [c]ourt via petition for writ of mandamus on December 4, 2025, . . . the writ of possession nevertheless executed on December [5], 2025, before this [c]ourt could rule. This appeal is not moot.” Cf. In re Tyson, No. 02-25-00667-CV, 2025 WL 3492586 at *1 (Tex. App.—Fort Worth Dec. 4, 2025, orig. proceeding). He then raises four “independent grounds to preserve the controversy”—none of which address whether he has a meritorious claim of right to current, actual possession of the apartment. 5  Because the possession issue is moot, we must vacate the trial court’s judgment of possession. See Marshall, 198 S.W.3d at 785–90 (holding that because the “case [wa]s moot . . . the court of appeals erred [by] dismissing only the appeal and leaving the trial court’s judgment in place”). Nevertheless, issues independent of possession— like past-due rent and attorney’s fees—remain reviewable on appeal. See Sherman, 2025 WL 2989761, at *2. Because the appealed-from judgment awarded Warren Inn past- due rent and attorney’s fees and because Tyson purportedly raises appellate issues that are independent of possession, we will address his complaints. B. Tyson’s Issues Are Inadequately Briefed In his brief, Tyson purports to raise six issues: Issue One: Whether the trial court committed reversible error by setting the first trial in this contested case with only nineteen days’ notice, in violation of Texas Rule of Civil Procedure 245, which mandates a minimum of forty-five days’ notice for the first trial setting absent written consent of all parties. Issue Two: Whether the trial court committed reversible error by combining Appellant’s Verified Plea in Abatement—a threshold challenge to the court’s authority to proceed—with a non[]jury trial on the merits, scheduling both for the same date and time on only nineteen days’ notice, and by denying Appellant’s request for additional time to have his multiple pending filings heard separately. Issue Three: Whether the trial court committed reversible error by selectively refusing to schedule or hear four of Appellant’s six pending filings—the Objection to Unlawful Appearance of Counsel, the Motion to Strike Counsel, the Motion to Stay Proceedings, and the Notice of Hearing Request on Equity Matters—while setting only the Plea in Abatement for hearing alongside the merits trial, thereby denying Appellant the benefit of his timely-filed defensive challenges. 6  Issue Four: Whether the trial court committed reversible error by entering what was effectively a default judgment against Appellant, who had filed an Original Answer, a Verified Plea in Abatement, multiple motions and objections, a Counterclaim, and an Affidavit of Harm— demonstrating continuous and active participation in the litigation— without providing constitutionally adequate notice that dispositive action could result from nonappearance at a proceeding set on only nineteen days’ notice. Issue Five: Whether the Final Judgment entered on August 27, 2025, is defective and interlocutory because it failed to dispose of Appellant’s live Counterclaim filed on August 26, 2025, rendering it insufficient as a final, appealable judgment under the one-final-judgment rule. Issue Six: Whether the Final Judgment entered on August 27, 2025 is void ab initio because Appellant filed his Notice of Removal in the United States District Court before the trial court entered judgment, thereby divesting the state court of jurisdiction under 28 U.S.C. § 1446(d); whether the case should have returned to its pre[]judgment posture upon remand rather than proceeding on a void judgment; and whether the trial court’s November 20, 2025 Order Extending the Writ—entered after the federal remand but based on the void August 27 judgment—is independently void. In the “Summary of the Argument” section of his brief, Tyson argues that these alleged errors “reveal a systematic denial of [his] right to due process that has resulted in catastrophic and ongoing harm.” Tyson’s brief then sets forth the purported “[s]tandard[s] of [r]eview” for each of his issues and explains how each issue was allegedly “preserved by [his] timely filings.” Within these sections of his brief, Tyson numbers his issues from “Issue I” to “Issue VIII.” He does not identify any standard of review for “Issue VII” but asserts 7 that it was preserved “by the Affidavit of Harm.” For “Issue VIII,” Tyson labels it as “cumulative constitutional deprivation.” 1. Pro Se Litigants and Inadequate Briefing A pro se litigant is held to the same standards as a licensed attorney and must comply with applicable laws and rules of procedure. Mansfield State Bank v. Cohn, 573 S.W.2d 181, 184–85 (Tex. 1978); Castro v. Am. Express Nat’l Bank, No. 02-23- 00196-CV, 2024 WL 3059046, at *3 (Tex. App.—Fort Worth June 20, 2024, no pet.). Thus, although Tyson is proceeding pro se, we cannot grant him any special accommodation. Under Texas Rule of Appellate Procedure 38.1, an appellant’s brief must contain “a clear and concise argument for the contentions made, with appropriate citations to authorities and to the record.” Tex. R. App. P. 38.1(i); see ERI Consulting Eng’rs, Inc. v. Swinnea, 318 S.W.3d 867, 880 (Tex. 2010) (recognizing that the rules of appellate procedure “require adequate briefing”). Merely uttering brief, conclusory statements unsupported by citation to authorities or to the record does not satisfy briefing requirements and presents nothing for this court to review. In re J.D., No. 02- 24-00515-CV, 2025 WL 2810523, at *2 (Tex. App.—Fort Worth Oct. 2, 2025, no pet.); Birnbaum v. Law Offices of G. David Westfall, 120 S.W.3d 470, 477 (Tex. App.— Dallas 2003, pet. denied). An inadequately briefed issue may not preserve error on appeal. In re P.S., 505 S.W.3d 106, 111 (Tex. App.—Fort Worth 2016, no pet.). The failure to “provide 8 substantive analysis of the legal issue presented results in a waiver of the complaint.” J.D., 2025 WL 2810523, at *2 (quoting Valadez v. Avitia, 238 S.W.3d 843, 845 (Tex. App.—El Paso 2007, no pet.)). An appellant waives the issues he attempts to raise on appeal if he does not adequately brief those issues by providing clear supporting arguments, substantive analysis, and appropriate citations to authorities and to the record. See Heffner v. Haverkamp, No. 02-25-00472-CV, 2026 WL 1700293, at *4 (Tex. App.—Fort Worth June 11, 2026, pet. denied) (concluding that appellant waived issues on appeal when arguments in brief were “a confusing, disjointed, rambling . . . stream of consciousness . . . without cogent analysis”); Player v. Booker, No. 02-24-00318-CV, 2025 WL 1006282, at *3 (Tex. App.—Fort Worth Apr. 3, 2025, no pet.) (holding that appellant waived complaint due to inadequate briefing because, among other reasons, she had failed to explain how the authorities cited in her brief supported her appellate argument); Shockley v. Yalk, No. 07-22-00128-CV, 2023 WL 1993683, at *2 (Tex. App.—Amarillo Feb. 14, 2023, no pet.) (declining to address arguments potentially raised on appeal when appellant’s brief was “disorganized, rambling, . . . and incredibly hard to decipher”); Purse v. DeJesus, No. 01-17-00855-CV, 2019 WL 237751, at *2–3 (Tex. App.—Houston [1st Dist.] Jan. 17, 2019, no pet.) (holding that appellant waived all issues because appellant’s brief did not contain any appropriate argument, analysis, discussion, or support for his purported issues). We are required to construe appellate briefs liberally so as not to preclude the right to appellate review. See Tex. R. App. P. 38.9; J.D., 2025 WL 2810523, at *2. But 9 it is not an appellate court’s responsibility to identify “possible trial[-]court error, search[] the record for facts favorable to a party’s position, or conduct[] legal research to support a party’s contentions.” J.D., 2025 WL 2810523, at *2 (quoting In re J.O.A.M., Nos. 01-23-00691-CV, 01-23-00692-CV, 2024 WL 1169432, at *23 (Tex. App.—Houston [1st Dist.] Mar. 19, 2024, no pet.)). As the reviewing court, we are not required to search the appellate record, with no guidance from the briefing party, to determine if the record supports the party’s argument. Hall v. Stephenson, 919 S.W.2d 454, 466–67 (Tex. App.—Fort Worth 1996, writ denied). Nor are we required to “become advocates for a particular litigant” by performing our own research and developing argument for that litigant. Perkins v. Hicks, No. 02-19-00207-CV, 2020 WL 7393334, at *1 (Tex. App.—Fort Worth Dec. 17, 2020, no pet.). “Were we to engage in such activities, we would be abandoning our role as judges and taking on the role of advocate for that party.” J.O.A.M., 2024 WL 1169432, at *23. Inadequate briefing has become more common since the development of ChatGPT and other AI tools. See Wilcox v. Duran, No. 02-25-00643-CV, 2026 WL 2357615, at *3 & n.4, *5 (Tex. App.—Fort Worth Aug. 13, 2026, no pet.) (holding that pro se appellant who confirmed use of ChatGPT to prepare brief had waived complaint on appeal due to inadequate briefing when authorities cited in brief were inaccurately quoted and did not support the propositions for which she cited them); Byrd v. Vills. of Woodland Springs Homeowners Ass’n, No. 02-23-00078-CV, 2024 WL 3529431, at *4 n.12 (Tex. App.—Fort Worth July 25, 2024, no pet.) (overruling pro se 10 appellant’s issues as inadequately briefed and noting that court “c[ould ]not tell from [appellant’s] brief” if he had used ChatGPT or another AI tool because authorities cited in the brief did not exist); Ex parte Lee, 673 S.W.3d 755, 756, 757 & n.2 (Tex. App.—Waco 2023, no pet.) (holding that appellant, who was represented by counsel, had inadequately briefed his appellate issue and affirming trial court’s denial of habeas relief when it appeared that appellant’s brief had been prepared by AI because it cited authorities that did not exist and failed to include citations to the record); see also In re C.R., No. 04-24-00576-CV, 2026 WL 823060, at *6 (Tex. App.—San Antonio Mar. 25, 2026, no pet.) (Brissette, J., concurring) (“We are seeing an increase in pro se litigants who believe that taking on their own representation in court is as easy as pulling up ChatGPT on their browser.”). Because “ChatGPT currently lacks the ability to produce reliable and accurate results when given a legal query,” we strongly caution litigants against using ChatGPT or other AI tools to prepare legal documents and filings, including appellate briefs. David T. Laton, A Cautionary Tale of AI as a Research Tool for Lawyers, 70 Prac. Law. 42, 43 (2024); see C.R., 2026 WL 823060, at *6 (Brissette, J., concurring) (“ChatGPT can no more prepare you to meet the challenges of a complex legal matter . . . than it can teach you how to surgically remove a tumor . . . .”); AGiza v. Franklin, No. 04-25- 00099-CV, 2025 WL 2058089, at *2 n.1 (Tex. App.—San Antonio July 23, 2025, pet. ref’d) (noting pro se appellant’s apparent use of ChatGPT or other AI tool and cautioning litigants against doing the same). 11  2. Analysis It appears that Tyson may have used ChatGPT or another AI tool to prepare his brief. His brief includes citations to authorities that are fictitious or inaccurate, purports to quote language from cited authorities in which the quoted language does not actually appear, and cites authorities that do not state or support the proposition for which he cites them. Further, Tyson makes several conclusory statements in his brief, fails to provide any substantive analysis, fails to explain how his cited authorities support his arguments, and wholly fails to provide support for his arguments and factual assertions, and several of his arguments are hard to decipher. In his brief, Tyson addresses the “scope” of a forcible-detainer appeal. He contends that our review is not limited to the right of immediate possession because that limited scope does not apply when “the trial court lacked subject-matter jurisdiction” and “the procedural deprivation directly affected the possession determination itself.” He cites no support for the latter “exception.” For the former, he cites Cook v. Cameron, 733 S.W.2d 137, 140 (Tex. 1987) (op. on reh’g), for the proposition that “a void judgment may be challenged at any time in any court regardless of the proceeding’s scope.” But that case involves an appeal from a postjudgment suit seeking enforcement of the supreme court’s judgment affirming certain awards in a divorce decree. Id. at 138. And while it states that a judgment rendered without jurisdiction is void, Cook does not state the proposition for which 12 Tyson cites it. See id. at 140. Rather, it states only that “a void judgment may be collaterally attacked.” Id. In his first and fourth issues, Tyson complains about the trial court’s alleged failure to comply with the notice requirements of Rule 245. See Tex. R. Civ. P. 245. He argues that the trial court violated Rule 245 by setting the trial date without forty-five days’ notice—the trial court signed its order setting trial on August 8, 2025, and the trial was held on August 27, 2025. He also argues that the trial court erred by rendering a “post-answer default” judgment against him when he did not appear at trial. He contends—without support—that “[a] constitutionally deficient notice [of trial setting] cannot serve as the foundation for a valid post-answer default” and that if the notice “violates due process, then the defendant cannot be said to have been properly informed that dispositive action would follow from nonappearance.” Tyson argues that his first issue “alone requires reversal” because he was harmed by the trial court’s alleged failure to comply with Rule 245. He asserts that “[t]he harm is not merely presumed” and that “[t]he deprivation of due process is the injury.” He cites no authority to support these arguments. Within his arguments, Tyson purports to quote Blanco v. Bolanos, 20 S.W.3d 809, 811 (Tex. App.—El Paso 2000, no pet.), providing that the “[f]ailure to give the required notice constitutes lack of due process and is grounds for reversal.” That language does not appear anywhere in Blanco. See id. 13  Tyson also purports to quote this court, citing “Bell Helicopter Textron, Inc. v. Agusta S.p.A., 863 S.W.2d 138, 140 (Tex. App.—Fort Worth 1993, no writ),” for the proposition that the “failure to comply with Rule 245 ‘renders any first setting notice ineffectual.’” That case is fictitious. The cited volume and page number of the Southwestern Reporter take the reader to our sister court’s review of an exemplary- damages award in Motsenbocker v. Potts, 863 S.W.2d 126, 138 (Tex. App.—Dallas 1993, no writ). And our search for the case name “Bell Helicopter Textron, Inc. v. Agusta S.p.A.” is similarly unavailing. Tyson also cites Lopez v. Lopez, 757 S.W.2d 721, 723 (Tex. 1988), for the proposition that “if a defendant establishes that he did not receive proper notice, a new trial is warranted without further analysis,” and he asserts that the “deficient notice under Rule 245 satisfies this standard.” Lopez involved an appeal from a judgment distributing estate assets among remaining heirs and analyzed whether, under Craddock v. Sunshine Bus Lines, Inc., 133 S.W.2d 124 (Tex. 1939), the meritorious claim or defense requirement should be excused when a judgment is rendered without proper notice. 757 S.W.2d at 722. Lopez stands for the proposition that requiring a defendant who did not appear at trial to show that he had a meritorious defense as a condition for granting his motion for new trial violates due process. Id. at 723. Even if Lopez stood for the proposition for which Tyson cites, it is distinguishable because the defendant in Lopez, unlike Tyson, had no actual or constructive notice of the trial setting. Id. 14  Based on these deficiencies, we conclude that Tyson has waived his first and fourth issues due to inadequate briefing, see Tex. R App. P. 38.1(i), and we overrule those issues.3 In his second issue Tyson provides, without support, “[t]he [g]overning [s]tandard” that “[a] plea in abatement is a threshold challenge to the [trial] court’s authority to proceed.” He cites Wyatt v. Shaw Plumbing Co., 760 S.W.2d 245, 248 (Tex. 1988), for the proposition that “[t]he Texas Supreme Court has held that a plea in abatement should be determined . . . before the court proceeds to the merits.” But that case involves a conflict of jurisdiction between courts in different counties and stands for the proposition that when a “suit would be proper in more than one county, the court in which suit is first filed acquires dominant jurisdiction to the exclusion of 3 Even if Tyson had adequately briefed his first and fourth issues, we would still overrule them because Rule 245’s notice requirements do not apply to forcible- detainer suits. Rather, Rule 510—we refer to the version in effect at the time of the proceedings below—“applies to a lawsuit to recover possession of real property.” Tex. R. Civ. P. 510.1, see id. cmt. (providing that Rule 510 was “completely rewritten as a standalone rule” effective January 1, 2026). Under Rule 510, “[a]n eviction case appealed to county court will be subject to trial at any time after the expiration of 8 days after the date the transcript is filed in the county court.” Tex. R. Civ. P. 510.12; Richardson–Wiggins v. AH4R Props. Two, LLC, No. 02-15-00158-CV, 2016 WL 552016, at *4 (Tex. App.—Fort Worth Feb. 11, 2016, no pet.) (applying prior rules and stating that appellant’s notice argument “mistakenly relie[d] on” Rule 245 and that Rule 510 governed forcible-detainer suits). Here, the transcript was filed in the trial court on July 23, 2025, and the trial court held trial on August 27, 2025. And under Rule 510.16, “[i]f a defendant who has answered fails to appear for trial, the court may proceed to hear evidence and render judgment accordingly.” Tex. R. Civ. P. 510.16(a). After the judgment is rendered, “[n]o motion for new trial may be filed.” Tex. R. Civ. P. 510.18(i). The trial court was therefore permitted to try the case and render judgment even though Tyson did not appear. 15 other courts.” Id. Tyson’s analysis on this issue is wholly unsupported by any authority and provides only conclusory assertions that the trial court “had already determined [that] the plea would fail[ ] before hearing it”; that the trial court abused its discretion by denying his request for “additional time” because he was “a pro se litigant facing the loss of his home”; and that he was harmed by the abuse of discretion because the trial court “ensured that [he] could not adequately prepare” and “would not appear.” Further, he provides only two citations to the record in his analysis. Because he has failed to comply with the briefing requirements of Rule 38.1(i), we conclude that Tyson has waived his second issue due to inadequate briefing, and we overrule it. See Tex. R. App. P. 38.1(i). In his third issue, Tyson argues that the trial court “ignored” his pending motions and objections—his “Original Answer,” “Objection to Unlawful Appearance of Counsel,” “Motion to Strike Counsel,” “Motion to Stay Proceedings Pending Ruling on Plea in Abatement,” and “Notice of Hearing Request on Equity Matters and Verified Objections”—and thus “eliminated every procedural safeguard [he] had erected between himself and judgment.” He argues that this is reversible error because “[a] trial court has a duty to rule on pending motions” and that any judgment entered without ruling on pending motions is “tainted.” Tyson’s argument and purported analysis contain no citations to authorities. It is not this court’s responsibility to conduct legal research to support Tyson’s contentions. See J.D., 2025 WL 2810523, at 16 *2. Accordingly, we overrule Tyson’s third issue as inadequately briefed and thus waived. In his fifth issue, Tyson contends that the judgment is both interlocutory and “not a proper final judgment” because it failed to dispose of his counterclaim. Thus, according to Tyson, the judgment “could not support the issuance of a writ of possession,” and his counterclaim “was adjudicated without notice or hearing.” He cites Lehmann v. Har-Con Corp., 39 S.W.3d 191, 195 (Tex. 2001), for its proposition that “[a] judgment is final for purposes of appeal if it disposes of all pending parties and claims,” id., but he otherwise fails to support this issue with any citations to authorities. Tyson has waived this issue due to inadequate briefing, and we overrule it. 4 See Tex. R. App. P. 38.1(i); J.D., 2025 WL 2810523, at *2. In his sixth issue, Tyson argues that the judgment “is void ab initio” and that, therefore, the November 20, 2025 “Order Extending the Writ” is “independently void.” He cites the United States Code, 28 U.S.C. § 1446(d), and argues that because—according to the file stamps—the trial court signed its judgment twenty- nine minutes after he filed a copy of the notice of removal in state court, the trial Even if Tyson had adequately briefed this issue, we would still overrule it 4 because a county court at law lacks jurisdiction over counterclaims filed in a forcible- detainer action. See Hong Kong Dev., Inc. v. Nguyen, 229 S.W.3d 415, 435 (Tex. App.— Houston [1st Dist.] 2007, no pet.) (op. on reh’g); see also Tex. Prop. Code § 24.004(c) (“Counterclaims . . . are not permitted in eviction suits.”); Holloway v. Revelstoke Venture, LLC, No. 02-23-00375-CV, 2024 WL 191221, at *1 (Tex. App.—Fort Worth Jan. 18, 2024, pet. denied) (noting that a forcible-detainer action may resolve only a claim for possession and related claims for unpaid rent and attorney’s fees). 17 court did not have jurisdiction to sign the judgment, and the judgment is void. He then cites McEwen v. Harrison, 345 S.W.2d 706, 710–11 (Tex. 1961), as “directly controlling,” asserting that the supreme court held that “a state court has no jurisdictional power to render judgment when removal has been effected; such a judgment is a nullity and may be attacked as void.” But the supreme court actually held in McEwen that “appeal by writ of error or a bill of review to set aside the judgment [we]re the exclusive methods” to “have the default judgment [in a personal- injury suit] vacated or set aside” and that the trial court’s order vacating the default judgment was therefore void. Id. at 707, 711. Tyson also cites Hampton v. Union Pac. R.R. Co., 81 F. Supp. 2d 703, 705–06 (E.D. Tex. 1999), as having held that “when removal and a state-court action occur on the same day, validity turns on which event occurred first, as established by objective proof such as file[-]stamp times, clerk certifications, and ECF timestamps.” But Hampton involved a mailed notice of removal and an amended complaint that the plaintiffs filed the same day that the notice of removal was “received” by the state court but two days before the federal clerk received the notice. Id. at 706. Hypothetically applying Texas Rule of Civil Procedure 5, the Eastern District of Texas noted that it “could not find any cases with facts such as th[o]se” and held that it was “without jurisdiction” because the requirements of Section 1446(d) had not been met. Id. at 706–07. 18  Tyson otherwise fails to support his arguments that the judgment is void, and none of his arguments regarding the validity of the trial court’s order extending the writ are supported with citations to authorities. Accordingly, he has waived his sixth issue as inadequately briefed, and we overrule it.5 Tyson also purports to raise a seventh and an eighth issue, arguing that “the cumulative impact of the trial court’s errors warrants separate treatment to ensure this [c]ourt fully appreciates the consequences of the judgment under review” and that the alleged cumulative errors constitute a “constitutional injury” depriving him of due process and “mandat[ing] reversal.” In these issues, Tyson reiterates the other issues that he attempted to raise and similarly fails to provide citations to authorities or to 5 Inadequate briefing aside, it appears that Tyson’s notice of removal was not timely. The eviction trial was held at 1:30 p.m. on August 27, 2025. According to Warren Inn, the trial court rendered its judgment in open court after the evidentiary proceedings were complete, and the subsequent written motion merely memorialized the ruling. See Worsham v. Fid. Union Life Ins. Co., 483 S.W.2d 44, 46 (Tex. App.—Tyler 1972, writ ref’d n.r.e.) (noting that a judgment is effective once rendered and that subsequent reduction to written judgment is merely a clerical action). The appellate record does not contain a reporter’s record from the trial. See In re V.R., No. 02-25- 00421-CV, 2026 WL 2130242, at *3 (Tex. App.—Fort Worth July 23, 2026, no pet.) (“When, as here, we lack a reporter’s record of the dispositive hearing, we must presume that the missing portions of the record support the judgment.”). According to the court reporter, Tyson did not request the transcript or designate a reporter’s record. Tyson claims that no court reporter was present for the trial. Nevertheless, according to the Northern District of Texas to which Tyson attempted removal, Tyson filed his notice of removal after the trial court awarded judgment for Warren Inn, and the removal was untimely. Warren Inn Haltom City v. Tyson, No. 4:25-cv- 00932-O-BP, 2025 WL 3179244, at *1 (N.D. Tex. Oct. 23, 2025), report and recommendation adopted, 2025 WL 3172887 (N.D. Tex. Nov. 13, 2025). 19 the record, provides incomplete citations, or cites authorities that do not state the proposition for which he cites them. He also fails to provide any substantive analysis, and some of his arguments are hard to decipher. For example, Tyson asserts that his “void-judgment theory . . . is independent of any challenge to the qualifications of the presiding officer under the de facto officer doctrine” and, in support of this assertion, cites (1) a forcible-detainer appeal in which neither the validity of the judgment nor removal were issues and (2) a criminal appeal from a driving-while-intoxicated conviction. See Jimison v. MAEDC- Hulen Bend Senior Cmty., L.P., No. 02-23-00206-CV, 2024 WL 3282544, at *1 (Tex. App.—Fort Worth July 3, 2024, no pet.); Espinosa v. State, 115 S.W.3d 64, 66 (Tex. App.—San Antonio 2003, no pet.). Tyson has waived his purported seventh and eighth issues as inadequately briefed; we therefore overrule these issues. Because Tyson has inadequately briefed all the issues he attempts to raise on appeal, he has waived them. Accordingly, we overrule all of Tyson’s issues that are independent of possession. C. Unchallenged Portions of the Judgment Tyson does not challenge—or even mention in his brief—the trial court’s award of $2,150 in past-due rent; $1,075 in attorney’s fees; post-judgment interest; and costs to Warren Inn. Because he does not challenge these awards, we affirm these aspects of the judgment. See Sherman, 2025 WL 2989761, at *3 (vacating judgment of possession as moot but affirming award of attorney’s fees and costs). 20  III. Conclusion Having concluded that the possession issue is moot and having overruled all of Tyson’s issues that are independent of possession, we vacate the trial court’s judgment as to possession of the apartment and affirm the judgment in all other aspects. See Bowman v. KWA202, LLC, No. 02-22-00216-CV, 2023 WL 2607754, *3 (Tex. App.— Fort Worth Mar. 23, 2023, no pet.). /s/ Wade Birdwell Wade Birdwell Justice Delivered: October 22, 2026 21