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Stacy Debnam and Dr. Matt Debnam v. Watts Pool Service, Inc.

2026-07-07

Authorities cited

Opinion

majority opinion

Opinion issued July 7, 2026

In The

Court of Appeals

For The

First District of Texas

NO. 01-26-00176-CV

STACY DEBNAM AND DR. MATT DEBNAM, Appellants

V.

WATTS POOL SERVICE, INC., Appellee

On Appeal from the 269th District Court

Harris County, Texas

Trial Court Case No. 2021-71293

MEMORANDUM OPINION

“Unless specifically authorized by statute, Texas appellate courts have

jurisdiction to review only final judgments.” Bison Bldg. Materials, Ltd. v. Aldridge,

422 S.W.3d 582, 585 (Tex. 2012); see also Wells Fargo Bank, N.A. v. Munson, No.

01-25-00434-CV, 2025 WL 2956235, at *2 (Tex. App.—Houston [1st Dist.] Oct. 21, 2025, no pet.). “A judgment issued without a conventional trial is final for

purposes of appeal if and only if either it actually disposes of all claims and parties

then before the court, regardless of its language, or it states with unmistakable clarity

that it is a final judgment as to all claims and all parties.” Wells Fargo Bank, N.A.,

2025 WL 2956235, at *4 (internal quotation marks and citations omitted).

Appellants’ Fourth Amended Petition asserts claims for breach of contract,

violations of the Texas Deceptive Trade Practices Act (“DTPA”), breach of express

and implied warranties, negligence, gross negligence, negligent hiring, private

nuisance, intentional infliction of emotional distress, fraud, and destruction of

property. It also asserts a claim under the Texas Uniform Declaratory Judgments

Act and seeks “attorney’s fees, interest, and costs of court” pursuant to section

37.009 of the Texas Civil Practice and Remedies Code.

In its September 2, 2025 order, the trial court granted summary judgment on

Appellants’ claims for breach of the implied warranty of habitability, destruction of

property, negligence, and gross negligence, but denied summary judgment on the

claims for breach of contract, DTPA violations, breach of express warranty, fraud,

private nuisance, and exemplary damages. The order further noted that other

implied-warranty claims remained pending because they were not challenged. In its

December 8, 2025 order, the trial court granted summary judgment on the claims for

breach of contract, DTPA violations, breach of express and implied warranties,

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private nuisance, and fraud. The court further ordered that Appellants “shall recover

nothing” from Appellee.

Neither summary-judgment order expressly addresses Appellants’ request for

attorney’s fees under the Uniform Declaratory Judgments Act. See TEX. CIV. PRAC.

& REM. CODE § 37.009. But “[c]ourts must . . . expressly dispose of requests for

attorney’s fees under discretionary fee-shifting statutes that do not require the

requesting party to prevail.” Sealy Emergency Room, L.L.C. v. Free Standing

Emergency Room Managers of Am., L.L.C., 685 S.W.3d 816, 825–26 (Tex. 2024)

(citing Tex. Civ. Prac. & Rem. Code § 37.009). A claim for attorney’s fees under

the Uniform Declaratory Judgments Act is an example of a discretionary fee-shifting

claim that a court must expressly address. Id.

We notified appellants that the appeal would be dismissed unless they

submitted a written response clearly explaining the basis for jurisdiction. Their

response failed to establish jurisdiction.

Accordingly, we dismiss this appeal for want of jurisdiction and dismiss all

pending motions as moot. See TEX. R. APP. P. 42.3(a).

PER CURIAM

Panel consists of Chief Justice Adams and Justices Rivas-Molloy and Guiney.

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