Judgment Final, Really.

Addressing the unfortunate complexity that can arise from the interaction of judgment-finality principles and sanctions motions, the Fifth Court held in Bandas Law Firm, P.C. v. Modjarrad & Assocs., P.C.

“Based on the text of [Tex. R. Civ. P.] 329b(g), the supreme court’s opinion in [Lane Bank Equip. v. Smith Southern Equip., Inc.], and this Court’s applicable precedents construing them, we conclude that a postjudgment motion for sanctions may qualify as a plenary-power-extending rule 329b(g) motion to modify the judgment, but only if the motion for sanctions specifically requests a substantive change in the existing judgment.”

No. 05-23-01115-CV (Apr. 25, 2025) (mem. op.).