In Re Patricia Ann Potts v. the State of Texas
CourtTexas Court of Appeals, 1st District (Houston)
Date FiledAugust 11, 2026
Docket01-26-00787-CV
StatusPublished
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Full Opinion
Opinion issued August 11, 2026
In The
Court of Appeals
For The
First District of Texas
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NO. 01-26-00787-CV
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IN RE PATRICIA ANN POTTS, Relator
Original Proceeding on Petition for Writ of Mandamus
MEMORANDUM OPINION
Relator, Patricia Ann Potts, a vexatious litigant subject to a pre-filing order,
and proceeding pro se, filed a petition for writ of mandamus alleging that the trial
court had failed to perform its ministerial duty “to rule on [r]elator’s pending
emergency motions.”1 Relator’s petition identified three separate lower court cause
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Relator’s petition for writ of mandamus fails to meet the requirements of the Texas
Rules of Appellate Procedure by failing to identify the real party/parties in interest
to the original proceeding and failing to identify the parties served with her original
proceeding. See TEX. R. APP. P. 9.5(e), 52.3(b). The petition for writ of mandamus
numbers, including cause number 267200185206, pending in the Harris County
Justice Court, Precinct 7, Place 2. However, relator failed to provide a mandamus
record or appendix, including, but not limited to, a mandamus record or appendix
containing any “pending emergency motions” which she alleges the respondent trial
court has refused to rule. See TEX. R. APP. P. 52.3(l)(1), 52.7(a)(1).
An appellate court may issue a writ of mandamus against judges of a district,
statutory county, statutory probate, or a county court in the court of appeals district.
See TEX. GOV’T CODE ANN. § 22.221(b). Relator’s petition for writ of mandamus
requests that this Court issue a writ of mandamus against a justice court. This Court
lacks mandamus jurisdiction over a justice court. See TEX. GOV’T CODE ANN.
§ 22.221(b)–(c); see also In re Castro, No. 02-23-00489-CV, 2024 WL 23627, at *1
(Tex. App.—Fort Worth Jan. 2, 2024, orig. proceeding) (mem. op.) (dismissing
petition for writ of mandamus for want of jurisdiction where relator challenged
“actions of a justice of the peace”); In re Garcia, No. 13-18-00651-CV, 2018 WL
6219254, at *2 (Tex. App.—Corpus Christi–Edinburg Nov. 28, 2018, orig.
proceeding) (mem. op.) (“This Court does not have jurisdiction to issue a writ of
mandamus against a justice of the peace.”).
identifies the respondent as the Honorable Sharon M. Burney, the presiding judge
of the Harris County Justice Court, Precinct 7, Place 2.
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Additionally, as noted above, relator has been declared a vexatious litigant
and is subject to a pre-filing order. The Clerk of this Court may not file an original
proceeding in a civil matter presented by a vexatious litigant subject to a pre-filing
order unless: (1) the relator first obtains an order from the local administrative judge
permitting the filing or (2) the relator is appealing from a pre-filing order declaring
her a vexatious litigant. See TEX. CIV. PRAC. & REM. CODE ANN. § 11.103(a), (d).
Relator’s petition for writ of mandamus does not challenge the order declaring her a
vexatious litigant, nor has relator provided any indication that she obtained
permission prior to filing this original proceeding.
Accordingly, we conclude that we lack jurisdiction to grant the mandamus
relief requested by relator. We therefore dismiss relator’s petition for writ of
mandamus for lack of jurisdiction. We dismiss any pending motions as moot.
PER CURIAM
Panel consists of Justices Caughey, Johnson, Dokupil.
3