Ninth Court Reverses Default Judgment in $1.3M Operating Agreement Dispute Over E-Filing Deadline Calculation Under Rule 21(f)(5)

The Beaumont Court of Appeals reversed a $1,379,281.69 default judgment against Proline Energy Resources in an oil and gas operating agreement dispute, holding that the trial court erred in refusing to consider a motion for new trial based on lack of plenary power. The court determined the motion was timely under Texas Rule of Civil Procedure 21(f)(5) where it was transmitted to the electronic filing service provider before midnight on the due date, despite subsequent technical failures and clerk's office rejections.