Gary E. Patterson & Associates, P.C. v. Holub

Appellant, Gary E. Patterson & Associates, P.C. ("the Law Firm"), appeals a take-nothing judgment rendered, upon various motions for summary judgment, against it and in favor of appellees, Houston Title Company ("HTC") and Ronald W. Holub and Mary R. Holub (together, "the Holubs"). We determine (1) whether the trial court erred in rendering judgment, upon the traditional summary-judgment motion of the Holubs and HTC, declaring that an abstract of judgment recorded by the Law Firm did not create a valid lien; (2) whether the trial court erred in implicitly denying the Law Firms hybrid cross-motion for summary judgment which asserted that the same abstract of judgment created a valid judgment lien; (3) whether the Holubs and HTCs no-evidence summary-judgment motion was legally sufficient; (4) whether the Law Firm has challenged on appeal every basis for no-evidence summary judgment below; (5) whether we must reach issues relating to aspects of the Holubs and HTCs no-evidence summary-judgment motion that were not a basis for the trial courts ruling or that concern an individual who is not a party on appeal; and (6) whether material fact issues precluded the trial court from granting the Holubs and HTCs no-evidence summary-judgment motion on any of the Law Firms remaining causes of action for damages. We affirm.