In Re Elizabeth Thomas v. the State of Texas
CourtTexas Court of Appeals, 1st District (Houston)
Date FiledJune 23, 2026
Docket01-26-00619-CV
StatusPublished
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Full Opinion
Opinion issued June 23, 2026
In The
Court of Appeals
For The
First District of Texas
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NO. 01-26-00619-CV
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IN RE ELIZABETH THOMAS, Relator
Original Proceeding on Petition for Writ of Mandamus
MEMORANDUM OPINION
Relator Elizabeth Thomas, acting pro se, filed a petition for writ of mandamus
challenging the county courtβs June 6, 2026 order dismissing her underlying action
for failing to obtain prefiling permission after having been declared a vexatious
litigant.1 See TEX. CIV. PRAC. & REM CODE Β§Β§ 11.102(a), 11.1035(b). Although the
1
The underlying case is Elizabeth Thomas v. Worth National Title Company, LLC
D/B/A McKnight Title, Worth National Insurance Company, and Naga V. Tran,
cause number 1277047, pending in the County Civil Court at Law No. 5 of Harris
County, Texas, the Honorable Jermaine Thomas presiding.
mandamus petition is directed at the county court, Relator also challenges the
November 16, 2023 order of the 80th District Court of Harris County declaring her
a vexatious litigant by asserting that the county court should have disregarded the
order.2 We deny the petition.
PER CURIAM
Panel consists of Justices Guerra, Gunn, and Morgan.
2
The vexatious litigant order was issued in James Allen and Allan Haye v. P.C.F.
Properties in TX, LLC v. Elizabeth Thomas, James M. Andersen, and JPMorgan
Chase Bank, N.A., No. 2020-35780 (80th Dist. Ct., Harris County, Tex., Nov. 16,
2023). See Office of Court Administration, List of Vexatious Litigants Subject to a
Pre-Filing Order, https://www.txcourts.gov/judicial-data/vexatious-litgants/ (last
visited June 19, 2026).
2