Substantive error about liability = successful restricted appeal

A restricted appeal examines “the face of the record” for error in a default judgment case. That review often focuses on procedural matters – mistakes in the return of service, inadequate pleading to invoke the long-arm statute, etc. – but can also focus on substance, as occurred in Haynes v. Gay. The appellants, members of the relevant LLC, successfully showed that the debt sued upon arose before the LLC forfeited its charter, and thus could not have been individually liable upon that debt. No. 05-17-00136-CV (Feb. 8, 2018). h