Dunn v. Dunn

In Dunn v. Dunn, 439 S.W.2d 830, 832 (Tex. 1969), the Court simply affirmed the validity of oral pronouncements from the bench by holding that, once a trial court orally renders judgment in open court, its entry of a written judgment is purely a ministerial act. Dunn, 439 S.W.2d at 832. The Court did not hold that a district court may sign a written judgment, even one merely affirming an administrative decision that became enforceable by operation of law, despite the district court's having lost jurisdiction over the case. Nonetheless, the Court's opinion here allows this result. Contra State ex rel. Latty v. Owens, 907 S.W.2d 484, 486 (Tex. 1995) ("Judicial action taken after the court's jurisdiction over a cause has expired is a nullity.")