In forcible detainer suits where a landlord-tenant agreement forms the basis of the parties' rights, the proper defendant is generally the tenant or lessee of the property in question. See Anderson v. Chandler, No. 12-16-00299, 2017 WL 2829329, *3 (Tex. App.-Tyler June 30, 2017) (internal citations omitted) (“In most situations, the parties in a forcible detainer suit are in a landlord-tenant relationship.”).
"[W]ithout a landlord-tenant relationship, a justice court cannot determine the issue of immediate possession without first determining who has title to the property." Anderson v. Chandler, No. 12-16-00299-CV, 2017 WL 2829329, at *3 (Tex. App.-Tyler June 30, 2017, no pet.) (quoting Goodman-Delaney v. Grantham, 484 S.W.3d 171, 174 (Tex. App.-Houston [14th Dist.] 2015, no pet.)); see Boehl v. Richardson, No. 13-19-00021-CV, 2019 WL 6769876, at *3 (Tex. App.-Corpus Christi Dec. 12, 2019, pet. denied) (mem. op.).
Courts have found intertwined title and possession issues in cases where the parties disputed the existence of a landlord-tenant relationship. See Anderson v. Chandler, No. 12-16-00299-CV, 2017 WL 2829329, at *3-4 (Tex. App.-Tyler June 30, 2017, no pet.) (mem. op.) (held that Appellant's assertion of title through gift of property and absence of landlord-tenant relationship raised title issue that required resolution before a determination of right to immediate possession); Yarbrough, 455 S.W.3d at 283 (held that, because Appellants contend the deed of trust and substitute trustee's deed are void due to forgery, they raised an issue of title so intertwined with the issue of possession as to preclude jurisdiction in justice court); Goodman-Delaney v. Grantham, 484 S.W.3d 171, 175 (Tex. App.-Houston [14th Dist.] 2015, no pet.) (held that where Appellee attempted to evict her step-mother after inheriting home step-mother had shared with Appellee's father, in absence of landlord-tenant relationship, justice court did not have jurisdiction). The Meltons have shown there is a fact dispute over whether they paid for the land in full, whether they pledged the land as security, and thus whether there was a landlord-tenant relationship.