The sound of final dismissal

A well-known Zen koan involves the sound of one hand clapping. Similarly, JMJ Development, LLC v. Ramolia involved the Texas test for whether a judgment is final, which can be satisfied whether or not the judgment is, in fact, a resolution of all mattters in dispute:

Regarding finality, the trial court’s judgment states “This judgment finally disposes of all parties and claims and is appealable.” Appellants asserts this language conflicts with the language in the order granting summary judgment on “his claims” instead of granting summary judgment on all claims. However, nothing on the face of the order suggests that there is any claim or party that remains pending. Appellants’ argument might have merit had the judgment lacked the finality phrase. However, since the judgment included a finality phrase, it was clear and unequivocal, the record is irrelevant, and further analysis is prohibited.

No. 05-21-01100-CV (July 27, 2022) (mem. op.).