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In Re the Bank of New York Mellon F/K/A the Bank of New York, as Trustee for the Certificateholders of the CW ABS, Inc., Asset-Backed Certificates, Series 2007-1 v. the State of Texas

2026-08-27

Summary

Holding. The appellate court conditionally granted mandamus relief in part and denied in part, ordering the trial court to strike that portion of the Second Amended Petition reasserting claims under Finance Code section 392.304(a)(8) and any prior negligent misrepresentation claims based on conduct before the first trial, while permitting the trial to proceed on the remanded claims for breach of contract, the section 392.304(a)(14) TDCA claim, and any allegedly new negligent misrepresentation claim arising from conduct after the first trial.

This case concerns a remand on limited grounds after an appellate court previously reversed and rendered judgment on some claims while remanding others for a new trial. The Bank of New York Mellon sued the Halls over a home equity loan involving disputed modifications, missed payments, and alleged misrepresentations. In the prior appeal, the court had eliminated the Halls' negligent misrepresentation claim and their claim under Finance Code section 392.304(a)(8) (relating to TDCA violations) by rendering take-nothing judgments, while remanding only the breach of contract claim and the TDCA claim under section 392.304(a)(14) for new trial.

On remand, the Halls filed a Second Amended Petition that reasserted several claims the appellate court had already decided against them, including allegations under Finance Code section 392.304(a)(8) and a new negligent misrepresentation claim. The bank sought to strike portions of this amended petition as falling outside the scope of the appellate court's remand mandate. The trial court denied the motion to strike in its entirety. The bank then filed a mandamus petition arguing the trial court abused its discretion by permitting claims that contradicted the prior appellate judgment.

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

Key issues

  • Scope of appellate mandate on remand from jury trial verdict
  • Whether trial court abused discretion by permitting amended pleadings outside mandated claims
  • Adequacy of appeal as remedy when trial court exceeds appellate court's remand instructions
  • Permissibility of asserting new claims based on post-trial conduct versus reasserting previously decided claims

Procedural posture

This is a mandamus proceeding arising from a remand in a civil suit following reversal of a jury verdict on some claims and remand for new trial on limited claims.

Authorities cited

Opinion

majority opinion

In The

Court of Appeals

Ninth District of Texas at Beaumont

NO. 09-26-00204-CV

IN RE THE BANK OF NEW YORK MELLON F/K/A THE BANK OF NEW

YORK, AS TRUSTEE FOR THE CERTIFICATEHOLDERS OF THE CW

ABS, INC., ASSET-BACKED CERTIFICATES, SERIES 2007-1

Original Proceeding

136th District Court of Jefferson County, Texas

Trial Cause No. D-203632

MEMORANDUM OPINION

This matter was previously before this Court in an appeal from a final

judgment on a jury verdict, and we reversed the trial court’s judgment in part,

rendered judgment in part, and remanded the case for a new trial on liability and

damages, if any, as to only two of the plaintiffs’ claims. We remanded for a new trial

the claim under the Finance Code section 392.304(a)(14) and the plaintiffs’ breach

of contract claim, and we remanded the issue of attorney’s fees, if any. Bank of N.Y.

Mellon v. Hall, No. 09-23-00102-CV, 2025 Tex. App. LEXIS 3526 (Tex. App.—

Beaumont, May 22, 2025, no pet.). On remand in the trial court, the Real Parties in

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Interest David Hall and Teresa Hall (“the Halls”), amended their pleadings to reassert claims on which this Court rendered a take-nothing judgment in the prior

appeal. In this mandamus proceeding, Relator, The Bank of New York Mellon f/k/a

The Bank of New York, as Trustee for the Certificateholders of the CW ABS, Inc.,

Asset-Backed Certificates, Series 2007-1 (“BNYM”), contends the trial court abused

its discretion by refusing to strike the Halls’ Second Amended Petition and limit the

new trial to the two claims we remanded—the breach of contract claim and the claim

for an alleged violation of Section 392.304(a)(14) of the Finance Code. Concluding

the trial court clearly abused its discretion in failing to strike some part of the new

petition and that the Relator lacks an adequate remedy by appeal, we conditionally

grant mandamus relief in part.

Background

We summarized and examined the parties’ disputes and the evidence from the

jury trial at length in our May 2025 opinion and we need not repeat it here. See id.

2025 Tex. App. LEXIS 3526, at **1-63. Briefly, the Halls obtained a $44,800 home

equity loan from New Century Mortgage Company in 2000. Id. at *2. In 2011, the

Halls obtained payoff information from the lender and submitted a check to the loan

servicer at the time. Id. In 2015, the Halls learned the loan servicer made an error

and approximately $19,000 had not been applied to the loan in 2011. Id. The Halls

sued BNYM in 2016, and in 2017, the parties entered into a Rule 11 settlement

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agreement. Id. at **2-3 After receiving and executing a release, the Halls non-suited

their case against BNYM. Id. In 2019, the Halls filed this lawsuit, docketed as Trial

Cause Number D-203632, and went to trial before a jury on their claims against

BNYM for breach of contract, negligent misrepresentation, and violations of the

Texas Debt Collections Act (“TDCA”). The jury found BNYM failed to comply

with the Rule 11 Agreement, that BNYM made false and misleading

misrepresentations, that BNYM made a negligent misrepresentation, and awarded a

total of over one million dollars in damages to the Halls. Id. at *3.

On appeal, BNYM argued (1) the trial court erred in refusing to submit a

question to the jury on whether there was a meeting of the minds by the parties as to

all essential terms of the Rule 11 Agreement; (2) the trial court erred in refusing to

set aside the jury’s verdict regarding the Halls’ claim for negligent misrepresentation

and claim for TDCA violations; (3) that even if the Halls established their right to

recover under the TDCA, the damages awarded for mental anguish, credit injury,

and value of the Agreement as received as compared to as represented were not

supported by legally and factually sufficient evidence; and (4) insufficient evidence

supported the amount of attorney’s fees awarded by the jury. Id. at **73-74.

We reversed the trial court’s judgment. Id. at *112. We held the Halls’

negligent misrepresentation claim was not barred by the economic loss rule because

the negligent misrepresentation claim was based on a separate injury and the

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economic losses were independent of those recoverable under the Halls’ breach of

contract claim. Id. at **78-80. We held, however, that there was legally and factually

insufficient evidence to support any award for past or future economic loss on their

claim of negligent misrepresentation and we rendered a take-nothing judgment on

that claim. Id.

On the Halls’ claims for TDCA violations, we held that because statements

regarding loan modifications do not concern the “character, extent, or amount of

consumer debt[,]” their claim that BNYM used “fraudulent, deceptive, or misleading

representation[s]” prohibited by Finance Code section 392.304(a)(8) fail as a matter

of law, and we rendered a take-nothing judgment on that claim. Id. at *86.

Evidence admitted at trial showed that in July of 2018 BNYM’s counsel told

the Halls’ attorney that BNYM was processing the loan modification, and in reliance

on BNYM’s representations, the Halls continued to send the payment amounts

BNYM told them to pay monthly along with the coupon from the coupon booklet

BNYM provided to the Halls, whereas the evidence at trial established that BNYM

did not decide to book the loan until August of 2021. Id. at *88. We held legally and

factually sufficient evidence supported the Halls’ claim that BNYM “represent[ed]

falsely the status or nature of the services rendered by the debt collector or the debt

collector’s business[]” as prohibited by Finance Code section 392.304(a)(14). Id. at

*87. We held, however, that factually insufficient evidence supported the amount

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awarded by the jury for past mental anguish, and we remanded the case for a new

trial on liability and damages recoverable for the alleged violation of Finance Code

section 392.304(a)(14). Id. at **96-97.

We remanded the case for liability and damages on the Halls’ breach of

contract claim because in their Motion to Enter Judgment they elected to recover

only on their claims for violations of the TDCA and negligent misrepresentation and

not their breach of contract claim. Id. at **111-12. Thus, we held they are entitled

to a new trial to present their claim for breach of contract and the claim for violation

of the TDCA under section 392.304(a)(14) together with applicable damages that

may be recoverable on those claims. Id. at *112. Because we reversed and rendered

on two claims and reversed and remanded on two claims, we reversed and remanded

the attorney’s fee award as well. Id. at **112-13.

Thus, we rendered a take-nothing judgment on the Halls’ claims for negligent

misrepresentation and for a violation of Finance Code section 392.304(a)(8). Id. We

remanded the case for a new trial on liability and damages, if any, as to the claim

under section 392.304(a)(14), we remanded the breach of contract claim for a new

trial on liability and damages, and we remanded the issue of attorney’s fees as to the

remanded claims. Id. at *113.

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The Halls’ Second Amended Petition

The Halls filed a Second Amended Petition after we remanded the case to

the trial court. The petition added “new” factual allegations:

7.18 Since the first trial of this matter, Bank has informed Plaintiffs of

their “new monthly payment,” which payment(s) have been timely

made by Plaintiffs as directed by Bank, only for said payments to be

once again and repeatedly deemed insufficient, such that Plaintiffs

suffer still another rolling default and the late fee penalties and negative

credit reporting associated therewith.

7.19 Additionally, Bank has informed Plaintiffs of escrow shortage(s),

which amount(s) when paid by Plaintiffs as directed by Bank have,

again, been deemed “insufficient,” despite Bank’s initial representation

to the contrary.

7.20 Bank’s serial inability to accurately and/or correctly communicate

the specific amount of debt owed on the Loan including, but not limited

to, the correct monthly payment and/or escrow balance is such that

Plaintiffs do not know the correct, specific amount owed on the Loan.

7.21 Each one of the representations, as described above, was made by

Bank negligently, grossly negligently, and/or recklessly without any

knowledge of the truth as a positive assertion.

7.22 From the time that Bank made these representations, as described

above, Plaintiffs believed them to be true as positive assertions made

by persons with knowledge of their truth. Specifically, that the Loan

Modification (as outlined in the Agreement) was being processed

and/or booked, that Bank had fixed/cured the issue (at or before trial),

and that various payments owed (coupon books, monthly payments,

escrow shortages, etc.) were the correct amounts actually due, such that

Plaintiffs relied, to their detriment, on Bank’s reckless and/or negligent

misrepresentations.

On their claim for breach of contract, in their Second Amended Petition the

Halls allege:

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10.01 Plaintiffs hereby adopt by reference the allegations contained in Section [VII] (“Facts”) hereinabove, and incorporate the allegations as if fully set forth at length herein.

10.02 Bank’s actions as described herein constitute a breach of contract committed upon Plaintiffs in violation of Texas law causing damage to Plaintiffs. Put simply, Bank’s conduct constitutes a breach of the

contract between Plaintiffs and Bank.

10.03 Here, there are two contracts, both of which Bank has breached. The first contract is the Agreement. The second contract is the Loan Modification.

10.04 At all times relevant, Plaintiffs and Bank had entered into the aforementioned contracts, which are attached hereto as Exs. 2 and 4, respectively.

10.05 Plaintiffs fully performed and/or substantially performed

Plaintiffs’ contractual obligations.

10.06 Bank, which accepted the terms of the contracts, [] breached the Contracts by failing to perform as agreed, which failures include, inter alia,:

(i) failing to book the Loan Modification;

(ii) failing to credit Plaintiffs’ cash payments against the

principal balance;

(iii) failing to pay Plaintiff $1,250 within 30 days of the signing

of the Release;

(iv) negatively reporting Plaintiffs’ credit and charging late fees

for payments, which occurred then and continues to occur now

as part of the negative feedback loop(s);

(v) by sending “inspectors” to the Home to assess it for

foreclosure and “beginning to institute foreclosures proceedings”

despite the previous agreement(s); and/or

(vi) other ways to be specified at trial.

10.07 Bank’s breach(es) caused injury to Plaintiffs.

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10.08 Bank’s breach(es) are (were) the proximate and/or producing

cause of Plaintiffs’ damages, such detailed more fully below (§ XIII. DAMAGES); Plaintiffs were also forced to retain the undersigned

attorneys to recover the damages that they have sustained as a result of the breaches of contracts.

10.09 Plaintiffs gave Bank notice as required by TEX. CIV. PRAC. &

REM. CODE § 38.002.10.[]

On their claim that BNYM violated the TDCA, the Halls allege:

11.01 Plaintiffs hereby adopt by reference the allegations contained in Section VII (“Facts”) hereinabove, and incorporate the allegations as if fully set forth at length herein.

11.02 Plaintiffs are “consumers” under the TDCA because the Loan is a consumer debt.

11.03 Bank can be sued under the TDCA because Bank is a debt

collector; additionally, Defendant BONY may be held liable for TDCA violations under a theory of vicarious liability.[]

11.04 Here, Bank violated the TDCA when it committed one or more

wrongful acts in violation of TEX. FIN. CODE § 392.304 against

Plaintiffs including, but not limited to,

(8) misrepresenting the character, extent, or amount of a

consumer debt, or misrepresenting the consumer debt’s status in

a judicial or governmental proceeding;

(14) representing falsely the status or nature of the services

rendered by the debt collector or the debt collector’s business;

and

(19) using any other false representation or deceptive means to

collect a debt.

11.05 These and other acts and/or omissions of Bank (are) were the

proximate and/or a producing cause of Plaintiffs’ damages who were

injured as a result of said acts and/or omissions and which damages are detailed more fully below (§ [XIII]. Damages).

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The Halls’ Second Amended Petition also alleges a claim for negligent

misrepresentation, asserting:

12.02 Plaintiffs do not assert any claim for negligent misrepresentation

for any act/omission that occurred prior to September 2, 2022.

12.03 Since September 2, 2022, Bank has made material

misrepresentation(s) about the Loan Modification, the Cure, the

monthly payments owed to Bank as part of the Loan, and as to escrow

shortages, which representations are independent of any contracts

between the parties herein.

12.04 Bank made these representations in the course of transaction(s)

in which Bank has a pecuniary interest.

12.05 Bank made the representations for the guidance of others, i.e.,

Plaintiffs.

12.06 Bank did not use reasonable care in obtaining/communicat[ing]

the information to Plaintiffs, who actually, justifiably, and reasonably

relied upon Bank’s representations in making payments.

12.07 Bank’s misrepresentation(s) proximately caused injury to

Plaintiffs, which resulted in Plaintiffs’ damages.

BNYM filed a motion to strike Plaintiffs’ Second Amended Petition because

it contains allegations that fall outside the scope of our mandate.

In response, the Halls argued we issued a general remand that allows the Halls

to amend their petition to add additional claims. After a brief non-evidentiary

hearing, the trial court denied BNYM’s motion to strike the Halls’ Second Amended

Petition.

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Mandamus Standard

We may issue a writ of mandamus to remedy a clear abuse of discretion by

the trial court when the relator lacks an adequate remedy by appeal. See In re

Prudential Ins. Co. of Am., 148 S.W.3d 124, 135-36 (Tex. 2004) (orig. proceeding);

Walker v. Packer, 827 S.W.2d 833, 839-40 (Tex. 1992) (orig. proceeding). “A trial

court clearly abuses its discretion if it reaches a decision so arbitrary and

unreasonable as to amount to a clear and prejudicial error of law.” Walker, 827

S.W.2d at 839 (internal quotations omitted). A trial court also abuses its discretion

if it fails to correctly analyze or apply the law, because a trial court has no discretion

in determining what the law is or in applying the law to the facts. See In re Prudential

Ins. Co. of Am., 148 S.W.3d at 135; Walker, 827 S.W.2d at 840.

We determine the adequacy of an appellate remedy by balancing the benefits

of mandamus review against the detriments, considering whether extending

mandamus relief will preserve important substantive and procedural rights from

impairment or loss. In re Team Rocket, L.P., 256 S.W.3d 257, 262 (Tex. 2008) (orig.

proceeding). An appeal is not an adequate remedy if the very act of proceeding to

trial—regardless of the outcome—would defeat the substantive right involved. In re

McAllen Med. Ctr., Inc., 275 S.W.3d 458, 465 (Tex. 2008) (orig. proceeding).

“Mandamus will issue to ensure compliance with this court’s judgment.” Lee v.

Downey, 842 S.W.2d 646, 648 (Tex. 1992) (orig. proceeding).

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Issues and Arguments

BNYM contends the trial court abused its discretion by refusing to strike the

Halls’ Second Amended Petition given the limited nature of our mandate. BNYM

further contends its lacks an adequate appellate remedy due to the trial court’s refusal

to strike the Second Amended Petition, thus forcing BNYM to defend against issues

at trial that are beyond the scope of our limited mandate.

The Halls contend we issued a general mandate that did not expressly prohibit

any amendment to their pleadings. They further contend an appeal provides an

adequate remedy. Finally, they argue laches bars BNYM’s complaint about their

amended pleading.

Analysis

When an appellate court “remands a case and limits a subsequent trial to a

particular issue, the trial court is restricted to a determination of that particular issue.”

Hudson v. Wakefield, 711 S.W.2d 628, 630 (Tex. 1986). The instructions given to a

trial court in the former appeal will be adhered to and enforced. Id. “In interpreting

the mandate of an appellate court, however, the courts should look not only to the

mandate itself, but also to the opinion of the court.” Id. The trial court is authorized

to take all actions that are necessary to give full effect to the appellate court’s

judgment, but the trial court has no authority to take any action that is inconsistent

or beyond the scope of that which is necessary to give full effect to the appellate

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court’s judgment and mandate. Phillips v. Bramlett, 407 S.W.3d 229, 234 (Tex.

2013).

We conclude that the Halls’ Second Amended Petition presents a claim that

is contrary to the scope of our mandate, and the trial court abused its discretion by

refusing to strike that part of the Second Amended Petition that reasserts a claim we

reversed and rendered. Most obvious is the reassertion of a claim under Finance

Code section 392.304(a)(8). We previously held that statements regarding loan

modifications do not concern the “character, extent, or amount of consumer debt[,]”

and the Halls have no claim under Finance Code section 392.304(a)(8), as a matter

of law, and we rendered a take-nothing judgment on that claim. Id. at *86. We

conclude the trial court abused its discretion in failing to strike that section of the

Second Amended Petition. Next, the Second Amended Petition reasserts a claim for

negligent misrepresentation again, even after we rendered a take-nothing judgment

on that claim. Plaintiffs allege in their Second Amended Petition, “Plaintiffs do not

assert any claim for negligent misrepresentation for any act/omission that occurred

prior to September 2, 2022.” And, on appeal the Halls contend that the negligent

misrepresentation claim is a “new claim” because it is based on actions and

misrepresentations that occurred by BNYM after September 2, 2022. Although

BNYM may question whether the Halls will be able to prove the necessary elements

of a “new” negligent misrepresentation claim, we cannot say the trial court abused

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its discretion in failing to strike that claim based solely on what is alleged in the

Halls’ Second Amended Petition.1 We note however, that BNYM may still file

special exceptions to the amended petition to require the Halls to specify the factual

basis for this or any other claim, and should have the opportunity to file a motion for

summary judgment on particular claims, or seek a motion for directed verdict at the

appropriate time if the Halls fail to establish sufficient evidence of any of their

claims.

Citing Simulis, L.L.C. v. Gen. Elec. Cap. Corp., the Halls argue a remand for

further proceedings consistent with the appellate court’s opinion reopens the case

entirely and allows a party to amend their pleadings freely. See 392 S.W.3d 729,

734-35 (Tex. App.—Houston [14th Dist.] 2011, pet. denied). In Simulis, the trial

court granted summary judgment on Simulis’s promissory estoppel and quantum

meruit counterclaims. Id. at 731. The appellate court affirmed the grant of summary

judgment on the promissory estoppel claim because Simulis’s reliance on alleged

promises of future business was unreasonable as a matter of law, but it found a fact

issue precluded summary judgment, reversed that part of the summary judgment,

1

We reject any argument that the Halls’ section 392.304(a)(8) claim should survive because it also is a “new” claim or is based on conduct that occurred after the first trial. Unlike the Halls’ negligent misrepresentation claim which failed because they presented legally insufficient evidence of damages at trial, their section 392.304(a)(8) claim failed because the conduct they allege is not actionable as a matter of law, regardless of how often it occurs.

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and remanded the case for further proceedings consistent with the appellate court’s

opinion. Id. at 731-32. On remand, rather than pursue its quantum meruit claim,

Simulis amended its pleading to add new counterclaims. Id. The trial court granted

special exceptions, then ordered Simulis to amend its pleading to assert a claim for

quantum meruit only, then granted a motion to dismiss the case with prejudice after

Simulis amended its pleading to assert claims other than promissory estoppel and

quantum meruit. Id. at 732. In a second appeal, the court concluded its opinion and

mandate made it clear that two claims were considered on appeal from the grant of

summary judgment, one of which was affirmed and one of which was reversed and

remanded. Id. at 735. The court of appeals explained that because the appellate court

had merely addressed the specific claims presented in the limited summary judgment

record before it, Simulis was free to amend its pleadings to add new claims except

as to those claims on which the appellate court rendered summary judgment. Id. at

735.

In contrast to Simulis, the judgment we reversed in the first appeal was not a

summary judgment, which could only affect claims challenged in the motion for

summary judgment, but a judgment on a jury verdict that adjudicated all claims that

were brought or could have been brought between the parties. We reversed and

rendered judgment for BNYM on certain claims, and we only remanded the breach

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of contract claim and the claim under the Finance Code section 392.304(a)(14),

including the attorney’s fees that might be recoverable on those specific claims.

Citing In re W. Star Trucks US, Inc., the Halls argue a trial court’s decision to

permit an amended pleading is inherently discretionary and not amenable to

mandamus because the relator has an adequate remedy through appeal to seek review

of the denial of the motion to strike. See 112 S.W.3d 756, 763 (Tex. App.—Eastland

2003, orig. proceeding). Here, however, the trial court lacks the discretion to exceed

our mandate on remand. Phillips, 407 S.W.3d at 234.

The Halls argue we should apply the doctrine of laches to deny mandamus

relief because the Halls amended their pleading eight months before BNYM filed its

motion to strike in the trial court. The Halls mentioned the eight-month gap between

the filing of their amended pleading and BNYM’s request to strike that pleading in

their response to the motion to strike, but they did not identify any specific prejudice

that they suffered because of the delay.

Generally, laches requires that a party show an unreasonable delay occurred

and a good faith and detrimental change in position by the real party in interest

resulted from the delay. In re Laibe Corp., 307 S.W.3d 314, 318 (Tex. 2010) (orig.

proceeding). The Halls complain that they drafted discovery requests and filed a

motion to compel discovery on their “new” claims, and they will need to repeat that

effort if they file another lawsuit against BNYM. The delay may have caused the

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Halls to waste some effort pursuing discovery, but they have not shown that the

delay resulted in a detrimental change in their position. See id. We decline to apply

the doctrine of laches to deny mandamus relief to BNYM.

Mandamus relief is appropriate to spare private parties and the public the time

and money that may be wasted by enduring eventual reversal of improperly

conducted proceedings. In re Essex Ins. Co., 450 S.W.3d 524, 528 (Tex. 2014); In

re Prudential Ins. Co. of Am., 148 S.W.3d at 136. We have already rendered a takenothing judgment on the Halls’ claims for negligent misrepresentation and on the

Halls’ TDCA claims other than their claim under Finance Code section

392.304(a)(14). See Hall, 2025 Tex. App. Lexis 3526, at **112-13. Appeal is not an

adequate remedy considering BNYM will be subjected to another cycle of discovery

and trial before our mandate would be enforced. We conclude the benefits of

mandamus relief outweigh the detriments. See In re Prudential Ins. Co. of Am., 148

S.W.3d at 136.

Conclusion

We conclude that the trial court clearly abused its discretion by denying

BNYM’s motion to strike part of the Second Amended Petition and that the relator

lacks an adequate remedy by appeal. We are confident that the trial court will vacate

its order denying BNYM’s motion to strike the Halls’ Second Amended Petition,

sign an order striking that part of the Halls’ Second Amended Petition that reasserts

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any claim we previously reversed and rendered, and that includes a prohibition on

filing any claim under Finance Code section 392.304(a)(8). That said, we agree the

trial court did not abuse its discretion in denying that part of the motion to strike

which sought to strike any claim for breach of contract or the claim under Finance

Code section 392.304(a)(14), or any alleged new cause of action, if any, that accrued

after the date of the first trial. A writ of mandamus shall issue only in the event the

trial court fails to comply.

PETITION CONDITIONALLY GRANTED IN PART AND DENIED IN

PART.

PER CURIAM

Submitted on June 23, 2026

Opinion Delivered August 27, 2026

Before Johnson, Wright and Chambers, JJ.

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