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Hughes v. Habitat Apartments

Supreme Court of Texas
Sep 10, 1993
860 S.W.2d 872 (Tex. 1993)

Summary

holding pauper's affidavit “sufficed as a pro se answer”

Summary of this case from Brown v. Apex Realty

Opinion

No. D-3519.

September 10, 1993.

Appeal from County Court at Law, Dallas County, Victoria F. Welcome, J.

James B. Pinson, Austin, Robert W. Doggett, Dallas, for petitioner.

C. Bryan Dunklin, Dallas, for respondent.


The issue in this case is whether a pauper's affidavit suffices as a pro se answer, entitling a defendant to notice of a hearing on a motion for default judgment. Ms. Hughes, a pro se defendant, orally answered Habitat's allegations in a forcible entry and detainer action in the justice court. Habitat prevailed, and Ms. Hughes appealed. Pursuant to her appeal in the county court, she filed a pauper's affidavit but failed to file a written answer as required by Texas Rule of Civil Procedure 753. Thus, the county court granted a default judgment in favor of Habitat, although Ms. Hughes was never notified of the hearing. The court of appeals affirmed the default judgment, holding that a pauper's affidavit did not entitle Ms. Hughes to notice of the hearing.

In Smith v. Lippmann, we held that a defendant's signed letter to the court clerk confirming receipt of the citation, identifying the case and parties, and providing the defendant's current address, sufficed as a pro se answer, entitling the defendant to notice of any further proceedings in the case. 826 S.W.2d 137 (Tex. 1992) (per curiam). Under these circumstances, because the pauper's affidavit supplied the type of information we found adequate for a pro se answer in Lippmann, we hold that Ms. Hughes was entitled to notice of the hearing on Habitat's motion for default judgment.

Pursuant to Texas Rule of Appellate Procedure 170, without hearing oral argument, a majority of the court grants the application for writ of error, reverses the judgment of the court of appeals, and remands the case to the trial court for further proceedings consistent with this opinion.

ENOCH, J., not sitting.


Summaries of

Hughes v. Habitat Apartments

Supreme Court of Texas
Sep 10, 1993
860 S.W.2d 872 (Tex. 1993)

holding pauper's affidavit “sufficed as a pro se answer”

Summary of this case from Brown v. Apex Realty

holding pauper's affidavit sufficed as pro se answer entitling defendant to notice of hearing

Summary of this case from HAMILTON v. SEC ST. BK

holding that pauper's affidavit sufficed as pro se answer entitling defendant to notice of hearing

Summary of this case from In re K.B.A

In Hughes, Hughes appealed a judgment against her in a forcible detainer action to the county court. See Hughes, 860 S.W.2d at 872.

Summary of this case from Stewart v. C.L. Trammell Prop.
Case details for

Hughes v. Habitat Apartments

Case Details

Full title:Levada HUGHES, Petitioner, v. HABITAT APARTMENTS, Respondent

Court:Supreme Court of Texas

Date published: Sep 10, 1993

Citations

860 S.W.2d 872 (Tex. 1993)

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