Harris County Case Study

Proposed — not Texas law The SAFE SAPCR Act is draft legislation. It has not been introduced, has not passed either chamber, and is not in effect. Nothing on this page describes a rule a Texas court applies today.

A documented timeline of how extrinsic fraud separates families

Disclaimer: This case study summarizes filings in public court records in Harris County, Texas, including the civil suit Willis v. Rendon Legal, PLLC and Laci Rendon, Cause No. 2025-95850, 189th District Court, which was dismissed with prejudice on 19 March 2026. Statements about specific individuals describe allegations made in those public filings. The defendants deny the allegations; no findings of misconduct have been entered. The case is presented to illustrate a systemic gap in service-of-process requirements that the SAFE SAPCR Act would close. This is not legal advice.

Last updated: August 26, 2026

Understanding What Happened

This case study documents a real SAPCR (Suit Affecting the Parent-Child Relationship) case in Harris County, Texas. The facts presented here come directly from public court records and official filings. They illustrate the systemic vulnerabilities that allow extrinsic fraud to occur.

The purpose of this documentation is not to make accusations, but to show how the current system enables abuse and why legislative reform is necessary to protect families.

Key Facts at a Glance

104 Days between personal service and the certificate
11+ Years since respondent lived at certified address
3 Emails ignored by attorney
14 Months before father learned of judgment

Texas 2023: Estimated Cost of Inaction

*Based on publicly available data and internal estimates. See methodology below.

~200K+ Family law cases filed annually (est.)
$48M* Estimated liability from fraudulent judgments
~$50 Approx. cost for proper constable service
$37.9M* Potential net savings (estimated)

Potential SAFE SAPCR Act Impact (Estimated)

*Projections based on internal analysis. Not independently verified.

~$10.8M* Estimated annual prevention cost
~$48M* Estimated liability currently incurred
~$37.9M* Potential net savings (estimated)
~350%* Estimated return on investment

Case References

  • SAPCR Case: District Court, Harris County (2024)
  • Concurrent Habeas Corpus Case: Harris County (filed 2023, DWOP'd June 4, 2024)
  • Bill of Review: District Court (2025)
  • Civil Action: District Court (2025)

Parties Involved (Per Public Records)

Petitioner's Attorney

Legal Representation

An attorney in East Harris County filed the SAPCR petition and Certificate of Last Known Address.

Respondent

Father

The parent who was personally served on April 6, 2024, wrote to petitioner's counsel six times requesting mediation and the served documents, but never received notice of the default hearing and learned of the judgment 14 months later.

The Court

District Court, Harris County

Granted default judgment on August 20, 2024 based on the Certificate of Last Known Address without independent verification of service.

Timeline of Events (From Public Records)

Latest case update: The Bill of Review trial has been reset to October 19, 2026. An amended Bill of Review was filed, the ex parte emergency motion was withdrawn, and service by constable is proceeding. Read the current update →

This is the complete, date-by-date record drawn from public court filings in Harris County, Texas. It documents Willis v. Rendon Legal, PLLC and Laci Rendon (Cause No. 2025-95850, 189th District Court), a civil suit alleging that attorney Laci Rendon of Rendon Legal, PLLC filed a Certificate of Last Known Address that was incorrect — 104 days after the respondent had been personally served at a different address. The defendants deny the allegations. Statements below describe what the pleadings assert; they are not findings of a court.

The timeline also covers the separate Bill of Review (Cause No. 202592876, 311th District Court), which seeks to set aside the underlying default order. Entries sourced to the First Amended Bill of Review are one party's verified allegations: as of the July 20, 2026 filing, the opposing party had not yet been served in that proceeding and has therefore had no opportunity to answer them.

March 19, 2024

Laci Rendon Files SAPCR Petition

Attorney Laci Rendon of Rendon Legal, PLLC files a Suit Affecting the Parent-Child Relationship (SAPCR) on behalf of Elizabeth Alvarado against the respondent father in the 311th District Court of Harris County, Texas (Cause No. 202417675). The petition was filed at 1:44 p.m. on March 19, 2024 in the 312th District Court and transferred to the 311th the following morning. It was supported by the March 19, 2024 affidavit of Elizabeth Alvarado, filed March 20, 2024, on which the application for a temporary restraining order rested; the clerk issued the restraining order and a notice setting a hearing for April 23, 2024 on March 21, 2024.

April 6, 2024

Personal Service in Baytown; Arrest and Property Withheld

The respondent traveled from New Orleans to Houston for a visit with his children. He was personally served with the SAPCR petition at a Baytown hotel at 6:15 p.m. on April 6, 2024, according to the process server’s sworn affidavit of service. He was arrested that night on an assault charge filed by Ms. Alvarado and booked the following day; the underlying police report records no visible marks or injuries. The pleadings in Cause No. 2025-95850 allege that the service documents were not returned with his other property, leaving him without a copy of the petition.

Why This Matters

Personal service establishes that the petitioner's side was able to locate the respondent at his actual location on this date. The pleadings rely on that fact when contesting the address certified 104 days later.

April 15, 2024

Executed Citation Filed April 15, 2024 — Contents Under Subpoena

The docket in Cause No. 202417675 reflects a restricted entry dated April 15, 2024, titled “Citation/Temporary Restraining Order (Executed).” The contents of that filing, including the return of service, are the subject of subpoenas duces tecum in the pending Bill of Review. The officer’s return form inside it is unexecuted; the proof of service is a process server’s sworn affidavit, which records personal service at a Baytown hotel and lists the documents delivered, among them the temporary restraining order and the order setting a hearing. The respondent’s position is that he was arrested the same day, that the served documents were not returned with his property, and that he was left without a copy of what he had been handed or knowledge of the cause number.

April 28 – May 9, 2024

Six Emails Sent to or Copied to Petitioner's Counsel

Respondent wrote to petitioner's counsel at her firm address requesting copies of the service documents and a path to mediation. Four messages were addressed to her directly and two more copied her:

  • April 28, 2024, 7:27 PM: Requested mediation and asked for “the papers I was served with at the hotel in Baytown”
  • April 28, 2024, 7:37 PM: Supplement to the same thread
  • April 29, 2024: Correspondence to the District Attorney’s office, copying counsel
  • April 30, 2024: Follow-up — “yet to hear back”
  • May 9, 2024: “3rd attempt requesting mediation,” including a contact phone number
  • June 9, 2024: Further correspondence to the District Attorney’s office, copying counsel

The First Amended Bill of Review states that these emails referenced the only cause number the respondent knew at the time — the Habeas Corpus case — because he had no knowledge the SAPCR existed, and that counsel never disclosed it.

The pleadings in Cause No. 2025-95850 allege that none of the emails were answered, and no reply from counsel appears in the exported thread. The exhibits attached to those pleadings establish that respondent's contact information was in counsel's possession.

May 31 & June 8, 2024

Petitioner Visits Respondent at Houston Hotel

Cash App and hotel records attached as exhibits to the Bill of Review document two visits by Elizabeth Alvarado to respondent at a hotel in Houston, Texas — 49 and 41 days before the Certificate of Last Known Address was filed. The pleadings rely on these records to allege that respondent's actual location was known to the petitioner.

June 3, 2024

Habeas Trial Setting — Citation Requested to New Orleans, Never Issued

Court records for Cause No. 202353496 show citation was requested to respondent’s actual New Orleans address and never issued. Two of those requests are in hand, filed December 27, 2023 and January 31, 2024, each directing service to that address “or anywhere found” and asking the District Clerk to issue. The court had the address too: the Scheduling Order signed March 21, 2024, which set this trial date, was addressed to respondent there. The case was dismissed for want of prosecution on June 4, 2024; the order recites that no party appeared for trial on the merits.

Why This Matters

A concurrent case in the same court had respondent’s out-of-state address on file — used by the petitioner’s side in its own service requests and by the court in its own scheduling order, four months before a different address was certified in the SAPCR. The pleadings cite this as evidence bearing on that certification.

July 19, 2024

Certificate of Last Known Address Filed Under Rule 239a

Laci Rendon signed and filed a Certificate of Last Known Address naming an address that both parties had abandoned in 2013 — eleven years before the SAPCR was filed. The address itself is omitted here; it is a residence now occupied by unrelated third parties.

The pleadings allege neither party had occupied it since 2013. The filing came 104 days after personal service in Baytown, after the six unanswered emails, and after the documented hotel visits. The plaintiff in Cause No. 2025-95850 alleges these facts demonstrate the certification was made with knowledge it was incorrect; the defendants deny the allegation. The claims were dismissed with prejudice at the pleadings stage on 19 March 2026, so no court has reached the merits of the dispute.

The Disputed Certification

Rule 239a requires the party taking a default judgment to certify the defendant's last known address. It imposes no duty to investigate and no verification requirement. This case is the SAFE SAPCR Act's central example of what that gap allows.

August 20, 2024

Default Judgment Entered Without Respondent's Appearance

Based on the filed Certificate of Last Known Address, the court authorized service by mail to the address listed. A default judgment was entered awarding sole managing conservatorship to the petitioner and restricting respondent to supervised visitation only. The pending Bill of Review (Cause No. 2025-92876) alleges that respondent received no actual notice of the proceeding before judgment.

August 20 – December 27, 2024

Unsupervised Visits Continue While the Order Goes Undisclosed

The First Amended Bill of Review alleges that during this period — beginning the day the default judgment was signed — the petitioner brought the children to the respondent for visits that were unsupervised, contrary to the supervised-only restriction in the order she had just obtained, and without disclosing that the order existed.

Why This Matters

A Bill of Review requires the petitioner to show the default was unmixed with his own fault. Conduct inconsistent with the order, continuing for months while its existence went unmentioned, is offered as evidence that the respondent had no way of learning about the judgment through ordinary diligence.

December 27, 2024

All Visitation Ends

The pleading states that visits between the respondent and the children ceased on this date and have not resumed — a period now exceeding eighteen months, and one that began while the respondent still had no knowledge that a court order governed the arrangement.

October 16, 2025

Respondent Learns of the Default Order — 14 Months Later

Respondent learned of the default custody order for the first time when the petitioner sent him a photograph of the Final Order — more than 14 months after it was entered. The pleadings in Cause No. 2025-95850 allege that the order was not otherwise communicated to him during that time.

The First Amended Bill of Review adds that supervised visitation was first mentioned to him on this date, two weeks after the Harris County Domestic Relations Office closed the visitation file, and that the order then produced had been in the petitioner's possession for fourteen months.

December 12, 2025

Bill of Review Filed in the 311th District Court

A Bill of Review (Cause No. 202592876) was filed in the 311th District Court — the court that rendered the default judgment — seeking to set aside the August 20, 2024 Final Order in Cause No. 202417675. It was filed together with an Ex Parte Emergency Motion for Temporary Possession of Children. The court did not rule on that emergency motion, and it remained pending on the docket for more than six months.

December 29, 2025

Civil Suit Filed in the 189th District Court

A separate civil suit (Cause No. 2025-95850) was filed in the 189th District Court of Harris County against Rendon Legal, PLLC and Laci Rendon individually, asserting claims for fraud, intentional infliction of emotional distress, abuse of process, and filing a fraudulent court record under Texas Civil Practice & Remedies Code § 12.002. This is a different proceeding from the Bill of Review and is before a different court.

January 6–9, 2026

Settlement Offer Extended; No Response

Plaintiff extended a settlement offer seeking nominal relief and procedural corrections rather than money damages. The defendants did not respond, and instead retained Kerr Wilson, P.C. as defense counsel.

January 2026

Law-Enforcement and Bar Referrals

A report was made to the Harris County Precinct 4 Constable's Office, and a perjury referral was submitted to the Harris County District Attorney's Office under Texas Penal Code § 37.02, directed at a sworn affidavit filed in Cause No. 202417675. Formal complaints were also filed with the State Bar of Texas, the Texas Real Estate Commission, and the Judicial Branch Certification Commission. Each of these was a complaint submitted by the plaintiff, not a finding by any agency.

Outcome

On March 20, 2026 the District Attorney's Intake Bureau responded that, based on the information and evidence in the report, “no charges will be filed or additional action taken by the District Attorney's Office.” No criminal charge has been filed against any person in connection with this matter, and no agency has made any finding of misconduct.

February 2–3, 2026

Defense Files Answer and Motion to Dismiss

Defense counsel filed an Answer and a pleadings-stage Motion to Dismiss, asserting that the alleged conduct is shielded by attorney immunity and the judicial proceedings privilege, and seeking $3,225 in attorney's fees against the plaintiff under Rule 91a.7. The Answer, in its affirmative defenses, pleads that plaintiff is “wholly responsible for his alleged damages.” The motion recites the docket gap regarding return of service, the unanswered emails and the statutory false-record claim under Tex. Civ. Prac. & Rem. Code § 12.002 in its background section, but its argument does not engage them: it rests entirely on attorney immunity and the judicial proceedings privilege.

February 9, 2026

Plaintiff Files Response Opposing Dismissal

Plaintiff opposed the dismissal motion, arguing under Cantey Hanger, LLP v. Byrd, 467 S.W.3d 477 (Tex. 2015), that conduct alleged to be fraud on the court is "foreign to the duties of an attorney," that the judicial proceedings privilege has been held not to immunize alleged fraud on the court, and that the § 12.002 false-record claim is independently viable. The response cited the 103-day gap, the absence of a return of service in the SAPCR docket, and the three unanswered emails. (That filing dated personal service to April 7, 2024; the process server’s sworn return, filed April 15, 2024, records April 6 at 6:15 p.m., which makes the gap 104 days. The figure is reproduced here as it was filed.)

February 13, 2026

Defendants Set Motion for Submission — No Oral Hearing Requested

Defendants set the dismissal motion for submission on March 9, 2026. No oral hearing is requested, meaning the court is asked to rule on the papers alone — without argument, without questions, and without any opportunity for the Plaintiff to address the bench.

February 19, 2026

Court Issues Scheduling Order — Trial Set for 2027

The trial court issues a Scheduling and Docket Control Order setting the case for trial on February 2, 2027, with full deadlines for expert designation, mediation, discovery, and dispositive motions. On its face, the case is moving toward a merits trial.

March 9, 2026

Dismissal Motion Submitted Without Hearing

The pleadings-stage dismissal motion is submitted to the court on the papers. No oral hearing is conducted. No questions are asked of either side.

March 19, 2026

Trial Court Grants Dismissal With Prejudice

Twenty-eight days after setting the case for trial, the trial court signed the defense's proposed order dismissing all claims with prejudice and awarding $1,500.00 in attorney's fees against the plaintiff. The order contains no findings of fact or conclusions of law. The boilerplate reference to "the response, if any" is one issue raised in the pending Motion for New Trial.

April 13, 2026

Plaintiff Files Motion for New Trial

Plaintiff files a Motion for New Trial and Request for Oral Hearing with Videoconference Appearance, challenging the dismissal on three grounds: the statutory false-record claim was never addressed, the court improperly resolved disputed facts on a pleadings-stage motion, and immunity doctrines do not shield knowing fraud on the court.

June 2, 2026

Motion for New Trial Overruled by Operation of Law

The court did not rule on the Motion for New Trial. It was therefore overruled by operation of law under Texas Rule of Civil Procedure 329b, seventy-five days after the judgment was signed. No hearing was held on the motion and no reasons were given.

The March 19, 2026 dismissal with prejudice stands. Across the whole of Cause No. 2025-95850, the claims were disposed of without an oral hearing, without findings of fact or conclusions of law, and without the case reaching a trial that had been set for February 2027.

Why This Matters

A motion overruled by operation of law is overruled because a deadline passed, not because a court weighed it and disagreed. The silence is the disposition. This is the second time in the same proceeding that a decision issued without explanation — the dismissal order itself contained no findings.

June 22, 2026

Letter Hand-Delivered to the 311th District Court

In the Bill of Review proceeding (Cause No. 202592876), plaintiff hand-delivered a formal letter to the court coordinator of the 311th District Court raising five procedural issues and making five corresponding requests — principally that the case had been misclassified as a conservatorship matter rather than a Bill of Review, that the pending ex parte motion be withdrawn, and that the trial setting be reset.

Full June 2026 update →

July 20, 2026

Amended Bill of Review Filed; Ex Parte Motion Withdrawn; Trial Reset to October 19, 2026

Three documents were filed together in Cause No. 202592876. The First Amended Bill of Review supersedes the original filed December 12, 2025 and becomes the operative pleading; it is verified and notarized, and it drops the request for ex parte relief. The Ex Parte Emergency Motion for Temporary Possession of Children — which had sat unruled on the docket since December 12, 2025 — was formally withdrawn. A Motion to Continue Trial Setting asked the court to reset the July 20, 2026 setting.

Withdrawing the ex parte motion removed the dependency that had held the case still for roughly six months, including holding back service. With it withdrawn, citation was requested under Texas Rules of Civil Procedure 99 and 106, with service by constable under Rules 103 and 106(a)(1). The trial is now set for October 19, 2026.

Why This Matters

The Bill of Review is the proceeding that could set aside the August 20, 2024 default order itself. It is a separate case from the civil suit against counsel and is not affected by that suit's dismissal.

Full July 2026 update →

Case Status — August 2026

July 2026

Bill of Review Set for Trial

Trial in the Bill of Review (Cause No. 2025-92876) set for October 19, 2026, in the 311th District Court.

August 2026

Citation Served; Answer Filed

Citation was personally served on the respondent-in-review by Harris County Constable Precinct 1. An answer was filed August 11, 2026, entering a general denial and objecting to assignment of the trial to an associate judge — meaning the elected judge of the 311th District Court will preside.

August 2026

Written Discovery and Subpoenas Issued

Written discovery (requests for admission, interrogatories, and requests for production) was served, and subpoenas duces tecum were issued for the complete court files and related records. Responses and productions are due in September 2026.

July 2026

Scheduling Order and Notice of Intent to Dismiss

The court signed a scheduling order on July 20, 2026 setting trial for October 19, 2026 at 10:00 a.m. The same order gives notice that the case may be dismissed for want of prosecution on the trial date if there is no citation, answer or waiver on file. Citation was served and an answer was filed on August 11, 2026.

August 2026

Method of Service on the Discovery and Subpoenas

The discovery requests were served under Texas Rule of Civil Procedure 21a by certified mail, signature required. Three subpoenas duces tecum were issued to custodians of records for the complete files of the two underlying causes. The contents of the discovery requests and the identities of the subpoena recipients are not published here.

The signed certificate of service is published, with the recipient's email address and street address removed: Certificate of Service, 24 August 2026 (PDF, redacted). It records service under Rule 21a by two methods — email, to the address the defendant stated in her own Original Answer, and certified mail, return receipt requested.

August 2026

Underlying Court File Obtained and Under Review

The complete underlying court file in Cause No. 202417675 — including the executed return of service, the March 19, 2024 supporting affidavit, and the default-judgment record — has been obtained and is being reviewed line-by-line against contemporaneous financial records, correspondence, and court filings from both underlying causes. Certified copies of out-of-state records referenced in the 2024 filings have been requested.

Declaration of Intent — October 19, 2026

On October 19, 2026, I will stand before the 311th District Court and ask it to vacate the default judgment entered August 20, 2024. I will not ask the court to take my word for anything. Every fact I present will come from the court’s own files and from records the parties themselves created — the dockets of both underlying causes, the service requests, the certificates, the correspondence, and the filings made in this case. I will prove that the certification that enabled the default was false when it was signed, that I was prevented from defending myself, and that the judgment was concealed from me for fourteen months. And when it is vacated, I will ask for what I have asked for from the beginning: a trial on the merits, and my children. The pleadings stating these grounds in full are public record in Cause No. 2025-92876.

Sources: Harris County District Clerk public records, Cause Nos. 202417675, 202353496, 2025-92876, 2025-95850. All documents available at www.hcdistrictclerk.com.

Has This Happened to You?

You're not alone. Thousands of parents across Texas have been separated from their children through fraudulent default judgments. Your story matters.

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Your experience could help change the law and protect other families.

This Must Change

The SAFE SAPCR Act would require mandatory constable service, attorney due diligence certification, and expedited remedies for fraud victims. No parent should lose their children through fraud.

Learn About the SAFE SAPCR Act Sign the Petition Contact Your Legislator

Sources

  • Harris County District Clerk public records
  • Texas Rules of Civil Procedure, Rule 239a
  • Case filings available through Harris County District Clerk's website
  • State Bar of Texas attorney records

All information presented in this case study is derived from publicly available court records and official sources. Individuals are named based on their roles in public legal proceedings as documented in court filings.

Learn More

Understand the legal concepts and get answers to common questions:

  • Legal Glossary – Definitions of SAPCR, extrinsic fraud, Bill of Review, Certificate of Last Known Address, and more
  • Frequently Asked Questions – What to do if you never received custody papers, how to respond to a SAPCR, and filing a Bill of Review
  • Resources – Step-by-step guides and helpful links for Texas family law