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Jose Saenz v. Kyle Bowman and McDonald's Corporation

2026-08-19

Summary

Holding. The Court of Appeals abated the appeal and remanded the case to the trial court to clarify whether its summary judgment was final as to all parties and claims, as uncertainties regarding jurisdiction prevented the appellate court from proceeding with its review.

Jose Saenz sued Kyle Bowman and McDonald's Corporation. McDonald's filed and the trial court granted a summary judgment motion in November 2025, dismissing all claims against McDonald's. However, the record indicated that Bowman may never have been properly served with the lawsuit and did not appear in the case. The trial court's order disposed of claims against McDonald's but did not expressly address whether claims against Bowman were also dismissed.

The appellate court identified a jurisdictional concern: it was unclear whether the trial court intended its judgment to be final as to all parties, including the unserved Bowman. To determine finality, the court applied a three-part test focusing on whether Saenz had abandoned efforts to serve Bowman. The evidence showed Saenz had hired a process server who attempted multiple times to serve Bowman and that Saenz had filed a motion for alternative service just days before judgment entered. This indicated Saenz still intended to serve Bowman, preventing the court from treating the judgment as final as to him.

Because the appellate court could not determine with certainty whether the trial court intended a final judgment disposing of all parties and claims, it stopped its review and sent the case back to the trial court for clarification of the judgment's scope and finality.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Finality of summary judgment as to unserved, non-appearing defendant
  • Appellate jurisdiction over judgments that do not expressly dispose of all parties
  • Whether plaintiff's ongoing service efforts indicate intent to proceed against remaining defendant

Procedural posture

Saenz appealed a summary judgment granted by the trial court in favor of McDonald's, which explicitly disposed of claims against McDonald's but did not expressly address the status of claims against co-defendant Bowman, who had apparently never been served.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

majority opinion

In The

Court of Appeals

Seventh District of Texas at Amarillo

No. 07-25-00399-CV

JOSE SAENZ, APPELLANT

V.

KYLE BOWMAN AND MCDONALD’S CORPORATION, APPELLEES

On Appeal from the 72nd District Court

Lubbock County, Texas

Trial Court No. DC-2024-CV-0966, Honorable John C. Grace, Presiding

August 19, 2026

ORDER OF ABATEMENT AND REMAND

Before DOSS and YARBROUGH and PRATT, JJ.

Pending before this Court is the purported appeal of the trial court’s summary

judgment signed on November 20, 2025. Because uncertainties remain concerning our

jurisdiction over this cause, we abate the appeal, remove it from our active docket, and

remand the matter to the trial court.

BACKGROUND

On July 25, 2024, Jose Saenz filed suit against Kyle Bowman and McDonald’s

Corp. McDonald’s answered and actively participated in litigation. Bowman, however,

made no appearance. On July 2, 2025, McDonald’s filed its traditional and no-evidence

motion for summary judgment. Continued several times, the trial court ultimately heard

the motion on November 13, 2025.

That same day, Saenz filed his motion for alternative service, alleging that Saenz

initially believed that Bowman had been properly served only to discover later that the

return of service was flawed. Since realizing the error, Saenz alleged, several

subsequent attempts to serve Bowman had been made without success. The record

indicates that the motion for alternative service was not expressly ruled upon.

Approximately one week later, on November 20, 2025, the trial court signed its

order granting McDonald’s traditional and no-evidence motion for summary judgment.

More specifically the trial court made the following pronouncements:

It is therefore ORDERED, ADJUDGED AND DECREED that McDonald’s

Corporation’s Traditional and No Evidence Motion for Summary Judgment

is granted. It is therefore ORDERED, ADJUDGED AND DECREED by the

Court that Plaintiff’s claims in the above-entitled and numbered cause

against Defendant McDonald’s Corporation are hereby dismissed with

prejudice to the refiling of same in any form.

IT IS FURTHER ORDERED, ADJUDGED AND DECREED that any crossclaims or cross actions pending herein are dismissed with prejudice to the

refiling of same in any form. All other relief not herein granted is hereby

denied. This Judgment shall be final for all purposes of all claims and

actions herein. Costs are taxed against the party incurring same.

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Saenz timely filed his notice of appeal, and the parties have submitted briefs in the cause.

The Court has begun its review of the cause and notes a potential jurisdictional defect.

APPELLATE JURISDICTION

The jurisdictional ambiguity centers on Bowman, who appears to never have been

served. He has not appeared in this matter, and the trial court’s summary judgment does

not specifically refer to Bowman or claims against Bowman.

Though the issue of our jurisdiction over this cause has not been raised by the

parties, we are nonetheless obligated to consider sua sponte issues that may affect our

jurisdiction. See M.O. Dental Lab v. Rape, 139 S.W.3d 671, 673 (Tex. 2004) (per curiam);

Buffalo Royalty Corp. v. Enron Corp., 906 S.W.2d 275, 277 (Tex. App.—Amarillo 1995,

no writ). “An appellate court lacks jurisdiction to review an interlocutory order unless a

statute specifically authorizes an exception to the general rule, which is that appeals may

only be taken from final judgments.” Qwest Commc’ns Corp. v. AT&T Corp., 24 S.W.3d

334, 336 (Tex. 2000) (per curiam).

In cases where there is no conventional trial on the merits and no statutory

exception applies, a judgment is final for purposes of appeal only if (1) it actually disposes

of all claims and parties before the court, regardless of its language or (2) the order states

with unmistakable clarity that it is a final judgment. See Guajardo v. Conwell, 46 S.W.3d

862, 863–64 (Tex. 2001) (per curiam); Lehmann v. Har-Con Corp., 39 S.W.3d 191, 192

(Tex. 2001).

Here, we have a summary judgment that appears to dispose of all claims against

McDonald’s, but it does not expressly dispose of claims against Bowman, the ostensibly

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unserved, non-appearing co-defendant. The judgment specifically dismisses with

prejudice Saenz’s “claims . . . against Defendant McDonald’s Corporation.” It goes to

declare finality for all purposes of “all claims and actions herein,” without decretal

language touching on the disposition of all parties.

In such a situation, we can consider the judgment to be final against the unserved,

non-appearing Bowman if the record establishes the following conditions:

(1) The trial court granted summary judgment expressly disposing of the

plaintiff’s claims against all parties named in the petition except one;

(2) So far as can be determined from the record, the remaining defendant was

never served with citation and did not file an answer; and

(3) Nothing in the record indicates the plaintiff ever expected to obtain service

upon the remaining party.

See Rape, 139 S.W.3d at 674 (determining that analysis as outlined in Youngstown Sheet

& Tube Co. v. Penn, 363 S.W.2d 230, 232 (Tex. 1962), still applied to the particular facts,

post-Lehmann).

If we find that the record establishes all three of the Penn conditions, then “the

case stands as if there had been a discontinuance as to [the unserved party], and the

judgment is to be regarded as final for the purpose of appeal.” Rape, 139 S.W.3d at 674

(quoting Penn, 363 S.W.2d at 232); see Wedgeworth v. City of Amarillo, No. 07-15-00301-CV, 2016 Tex. App. LEXIS 5241, at *4 (Tex. App.—Amarillo May 17, 2016, pet.

denied) (mem. op.) (applying Penn analysis and concluding judgment was final when

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“[t]he record provide[d] no indication [plaintiff] intended to proceed against [two unserved

defendants]”).

ANALYSIS

The first two prongs of the Penn analysis have been met. The trial court’s summary

judgment expressly disposed of Saenz’s claims against McDonald’s but did not expressly

dispose of claims against Bowman. Also, the record suggests Bowman was unserved

and did not file an answer. For the final prong of the analysis, we must evaluate whether

the record demonstrates Saenz held no expectation or intention of serving Bowman.

When Saenz discovered that Bowman had not been properly served, he enlisted

a new process server who, per his affidavit, made several attempts to effectuate service,

to no avail. Saenz then moved for the trial court’s leave to serve Bowman by alternative

means. He filed this motion in November 2025 and only days before the trial court granted

summary judgment. So, at the time judgment was entered, it would appear from Saenz’s

efforts and his motion for alternative service that Saenz expected or intended to serve

Bowman. Contrast Rebector v. Angleton Danbury Hosp. Dist., No. 14-08-00811-CV,

2010 Tex. App. LEXIS 5311, at *5 (Tex. App.—Houston [14th Dist.] July 8, 2010, pet.

denied) (mem. op.) (when record contained some indication that plaintiff expected or

intended to obtain service on defendant, concluding that Penn conditions were not

satisfied and noting that case was abated to permit parties to obtain final, appealable

judgment), with Sondock v. Harris Cty. Appraisal Dist., 231 S.W.3d 65, 67 n.1 (Tex.

App.—Houston [14th Dist.] 2007, no pet.) (in cause where summary judgment was

granted in favor of one defendant without reference to another, unserved defendant,

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proceeding to merits of case when, ostensibly, record supported conclusion that plaintiff

did not expect to obtain service on unserved defendant), and McDaniels v. Mittemeyer,

No. 07-03-00234-CV, 2004 Tex. App. LEXIS 2612, at *1 n.2 (Tex. App.—Amarillo Mar.

24, 2004, pet. denied) (mem. op.) (when nothing of record indicated that plaintiff

“continued to attempt or expected to obtain service upon” a co-defendant, deeming

summary judgment against all other defendants as final for purposes of appeal).

Thus, we are unable to conclude that the record establishes Saenz did not expect

or intend to obtain service on Bowman. The judgment fails to satisfy the third condition

of the Penn standard, and we are unable to definitively determine the finality of the

summary judgment signed November 20, 2025.

INSTRUCTIONS ON REMAND

When an appellate court is uncertain as to the trial court’s intent to finally dispose

of all claims and parties, it may abate the appeal to permit the trial court to clarify. See

Lehmann, 39 S.W.3d at 206; see also TEX. R. APP. P. 27.2 (authorizing intermediate

appellate court to abate an order to be modified so as to be made final); Nguyen v.

Nguyen, No. 07-24-00093-CV, 2024 Tex. App. LEXIS 5961, at *6 (Tex. App.—Amarillo

Aug. 19, 2024, order) (abating and remanding case when conflicting record evidence

concerning finality of judgment “preclude[d] our threshold determination of appellate

jurisdiction and the scope of the parties and issues before us”).

Accordingly—and without reaching the merits of the trial court’s judgment signed

November 20, 2025, or passing on substantive matters related to service—we abate this

appeal and remand the case to the trial court for clarification on the finality of its summary

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judgment. Accord Palma v. Young, 601 S.W.3d 799, 801 (Tex. 2020) (per curiam);

Lehmann, 39 S.W.3d at 206. The trial court is free to determine the appropriate and

applicable means by which it could make clear that its summary judgment is final as to all

parties and all claims and may include findings of fact and conclusions of law, should it

deem them necessary, to inform our jurisdiction over Saenz’s appeal. Alternatively, or

additionally, the parties may take the necessary step—be it severance, non-suit, or some

other means—to obtain a final judgment if the facts developed below so compel.

The trial court shall cause to be filed in this Court a supplemental clerk’s record

which contains additional filings by the parties, if any; the trial court’s orders, if any; and

any findings and conclusions that the trial court may deem relevant. The supplemental

clerk’s record should be filed with the Clerk of this Court on or before September 18, 2026.

IT IS SO ORDERED.

Per Curiam

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