In re Hefflefinger Partnership holds that a trial court, presiding over a post-judgment turnover proceeding, cannot adjudicate the substantive rights of a non-party by declaring a deed of trust void and reallocating sale proceeds. Specifically, the Fifth Court held that the turnover statute is a procedural collection device and does not authorize courts to resolve competing claims to property, or proceeds within the turnover action itself.

Because the statute “has no provision conferring authority on trial courts to decide the substantive rights of the parties properly before it in a turnover proceeding, let alone the rights of strangers to the underlying judgment,” the court held the trial court abused its discretion by voiding the lien and denying the lienholder any share of sale proceeds.

Mandamus relief was appropriate because the affected lienholder—who was not a party to the underlying judgment—lacked an adequate remedy by appeal. No 05-23-01091-CV, Oct. 2, 2025.