Memorandum Opinion Per Curiam, 14-26-00116-CV, February 05, 2026.
On appeal from the 257th District Court of Harris County.
Synopsis
The Relator sought a writ of mandamus to compel the trial court to vacate subsequent temporary orders and enter a final judgment based on a 2024 mediated settlement agreement. The Fourteenth Court of Appeals denied the petition, holding that the Relator failed to establish that the trial court committed a clear abuse of discretion or that there was no adequate remedy by appeal.
Relevance to Family Law
This proceeding underscores the procedural difficulty in enforcing Mediated Settlement Agreements (MSAs) through extraordinary writs when a trial court continues to exercise jurisdiction through interlocutory orders. While the Texas Family Code provides a high degree of finality to MSAs under Sections 6.602 and 153.0071, this case serves as a critical reminder that a trial court’s failure to immediately sign a decree—even in the face of a valid MSA—does not automatically entitle a party to mandamus relief. Practitioners must be prepared to specifically articulate why an ordinary appeal following a final judgment would be inadequate to rectify the trial court’s refusal to honor the settlement, especially when the trial court has opted to issue intervening temporary orders.
Case Summary
Fact Summary
The underlying litigation involved a family law dispute in the 257th District Court of Harris County. In 2024, the parties successfully reached a mediated settlement agreement intended to resolve their disputes. Despite the existence of this agreement, the trial court did not immediately sign a final judgment. Instead, on June 27, 2025, the trial court issued additional temporary orders. The Relator, Sarah Paige Biles, filed a petition for writ of mandamus in the Fourteenth Court of Appeals. She argued that the trial court had a ministerial duty to sign a judgment based on the 2024 MSA and that the court’s issuance of temporary orders more than a year later was an abuse of discretion that required vacatur.
Issues Decided
The court considered whether the Relator demonstrated that the trial court clearly abused its discretion by failing to enter judgment on the MSA and by issuing additional temporary orders, and whether the Relator lacked an adequate remedy by appeal.
Rules Applied
The court applied the standard for mandamus relief as articulated in In re Prudential Ins. Co. of Am., which requires the Relator to show both a clear abuse of discretion and the lack of an adequate remedy by appeal. The court also looked to the standards governing the entry of judgment on Mediated Settlement Agreements under the Texas Family Code, which generally require a trial court to enter judgment if the agreement meets specific statutory requirements, though the court’s memorandum focused on the failure to meet the overall mandamus burden.
Application
The court’s analysis centered on the Relator’s failure to bridge the gap between a trial court’s error and the necessity of an extraordinary remedy. The Relator essentially argued that the 2024 MSA acted as a bar to any further trial court action other than the entry of judgment. However, the appellate court found that the Relator did not provide a sufficient basis to prove that the trial court’s decision to issue temporary orders—and its refusal to sign the final judgment at this juncture—constituted a “clear” abuse of discretion.
Furthermore, the court focused on the “adequate remedy” prong of the mandamus test. Even if the trial court erred in failing to enforce the MSA, the Relator was required to show that the standard appellate process (appealing after a final judgment is eventually signed) would be insufficient to protect her rights. The court determined that the Relator failed to meet this burden, suggesting that the issues raised could be addressed through the normal course of litigation and subsequent appeal.
Holding
The court held that the Relator failed to demonstrate entitlement to mandamus relief. Because the Relator did not show that the trial court’s actions were a clear abuse of discretion or that she lacked an adequate remedy by appeal, the petition was denied.
The court further held that the Relator’s request to vacate the June 27, 2025, temporary orders did not meet the rigorous standards for the issuance of a writ, effectively leaving those orders in place as the litigation continues toward a final resolution.
Practical Application
For the practitioner, this case emphasizes that “binding” under the Family Code does not always mean “immediately enforceable via mandamus.” If a trial court refuses to sign a judgment on an MSA and instead sets the case for further temporary hearings or trial, the relator must do more than simply cite the statute. To succeed on mandamus, the practitioner must build a record showing that the intervening orders cause a type of harm—such as the permanent loss of property rights or an irreparable impact on a child’s environment—that cannot be undone by an appeal six to twelve months later. Without a specific showing of why an appeal is inadequate, the Fourteenth Court remains hesitant to interfere with the trial court’s interlocutory management of the docket.
Checklists
Pre-Mandamus Evaluation for MSA Enforcement
- Verify the MSA contains the specific “not subject to revocation” language required by Tex. Fam. Code § 6.602 or § 153.0071.
- Ensure the record contains a clear, written motion to entry and a transcript of the hearing where the trial court refused to sign the judgment.
- Document any specific, irreparable harm caused by the trial court’s delay or the issuance of new temporary orders (e.g., depletion of the community estate or disruption of a child’s stability).
- Evaluate if the new temporary orders address issues not covered by the MSA, which might justify the trial court’s continued exercise of discretion.
Strengthening the “Inadequate Remedy” Argument
- Contrast the cost and time of a full trial against the mandatory nature of the MSA.
- Highlight any specific rights that will be lost irretrievably if the case proceeds under the “wrong” orders.
- Cite specific Houston-area appellate precedents where mandamus was granted in the MSA context to show a “clear” abuse of discretion.
Citation
In re Sarah Paige Biles, No. 14-26-00116-CV, 2026 WL ______ (Tex. App.—Houston [14th Dist.] Feb. 5, 2026, orig. proceeding) (mem. op.).
Full Opinion
The full opinion can be found here: Full Opinion
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